Privacy and Confidentiality Notice

June 14, 2019

We at PharmEssor Group Corporation (“PharmEssor”), wholly-owned subsidiary of McKesson Canada Corporation ("McKesson Canada"), are committed to maintaining the privacy and security of our customers' personal information. Through this Privacy and Confidentiality Notice, PharmEssor wants to assure you of our commitment to privacy and security. Our privacy philosophy is based on the 10 fair information principles found in the Personal Information Protection and Electronic Documents Act (PIPEDA). We take our responsibility as regards to personal information very seriously and as such, a privacy officer who is accountable for the organization's compliance with the 10 fair information principles has been designated.

1 - Notice

If we collect information from or about you, we will tell you what information is being collected, how, by whom, and for what purposes.

2 - Access

We will let you update the personal information you have provided to us. We will also take steps to make sure that any updates you provide are processed in a timely and complete manner. If we collect personal information through our sites, we will maintain the information and allow you to update it at any time. We will continue to work on better access methods to allow you to update your information. Note that some PharmEssor sites may contain links to other sites that are beyond our control. Per section 8 of this document, we recommend that you read such sites' privacy policy before entering information.

3 - Choice

We will give you options about how the personal information you provide to us may be used. Before we use your personal information for any purpose, we will seek your decision as to whether or not you allow us to engage in that use. To exercise this choice, we will allow you to notify us of your preferences during the information collection process. If there are third parties that process PharmEssor data, we will require them to hold all personally-identifiable information confidential, and to use our customer information only for the purpose of fulfilling their business obligation. PharmEssor does not sell personally identifiable information to third party marketers.

4 - No Collection of Personal Information for Browsing Purposes

PharmEssor does not collect personal information about you unless you either (i) send an email message to PharmEssor; (ii) apply online for a position with PharmEssor, (iii) use any of the online Customer Access such as, without limitation, PharmaClik™, amongst others.

We do capture the paths taken as you move from page to page (i.e., your "click stream" activity). Information we collect on our websites may be used to enhance your use of these websites in ways such as:

• Organize the website in the most user-friendly way;
• Customize your browsing experience of this website;
• Communicate special offers, information and featured items to you, if you choose to receive such notices;
• Respond to your questions or suggestions.

5 – Use of Personal Information – General

McKesson Canada uses the information we collect to provide, maintain, protect and improve the quality of our services, to develop new products and services, and to protect McKesson Canada and its users.

Information we collect may be used to (the “General Purpose”):

• Activate your network services to connect to the mobile app or your selected pharmacy’s database;
• Perform diagnostic services such as error reporting in order to improve the mobile app;
• Identify usage trends;
• Perform data analysis and audits;
• Provide you with the products and services requested;
• Register you for a points card or other type of loyalty card;
• Process your photo development orders;
• Organize promotional activities and contact contest winners;
• Send you information about our products and services, our newsletters, email alerts for our online flyers and to answer your questions;
• Improve our advertising services, including targeting, retargeting, and excluding you from various offers;
• Improve and personalize our Website content;
• Use in marketing studies and surveys; or
• Design, improve or market products and services or provide you with information that might interest you.

6 - Use of Personal Information by Employees of PharmEssor, McKesson Canada, McKesson Corporation and other Affiliated Companies

Certain employees will be provided with information about a website visitor in order to serve that visitor's needs and provide the visitor with information regarding specific products. PharmEssor's employees as well as those of McKesson Canada, McKesson Corporation and other affiliated companies are instructed to use strict standards of care in handling the personal and confidential information of PharmEssor's clients. Employees who do not conform to PharmEssor's confidentiality rules are subject to disciplinary sanctions which may include dismissal.

YOU HEREBY EXPRESSELY CONSENT TO THE DISCLOSURE BY PHARMESSOR OF YOUR PERSONAL INFORMATION TRANSMITTED THROUGH THIS SITE TO PHARMESSOR'S EMPLOYEES AS WELL AS THOSE OF MCKESSON CANADA, MCKESSON CORPORATION AND OTHER AFFILIATED COMPANIES LOCATED IN EITHER CANADA OR THE UNITED STATES.

7 – Sharing of Personal Information

McKesson Canada may share information with governmental authorities, companies, organizations or individuals outside of McKesson Canada if the information is to be used for the General Purpose, or if we have a reason to believe that access, use, preservation, or disclosure of that information is reasonably necessary to:

• Meet applicable laws, regulations, legal processes or enforceable governmental requests.
• Enforce applicable Terms, including investigation of potential violations.
• Detect, prevent, or otherwise address fraud, security or technical issues.

(collectively, “Required Disclosures”).

McKesson Canada may divulge your personal information to the following entities outside of McKesson Canada for the General Purpose:

• Any subsidiary, affiliate, or entity otherwise connected with McKesson Canada;
• McKesson Canada’s third party suppliers of products and services, organizations or individuals whose services have been retained to perform certain duties on our behalf (for example, providers of photo development services, promotion management, data processing and electronic payment providers or record management suppliers, marketing services, etc.) McKesson Canada takes all contractual or other measures necessary to ensure that its employees and all providers of products or services use your personal information only for purposes of providing you or McKesson Canada with these products or services and that they provide such personal information with a level of protection comparable to that provided by McKesson Canada to personal information in its possession;
• Any entity resulting from a merger or change in control of McKesson Canada, in whole or in part, provided that the parties enter into an agreement that this information will only be collected, used or communicated as required to meet the objectives of the commercial transaction; or
• Any public authority as required by law.

8 - Cookies

PharmEssor may use cookies (very small text files that are downloaded on your hard disk from certain web pages of the site) to estimate its size audience. Cookies are then used to determine the extent of repeated use and the extent of use by a registered user versus an unregistered user to help PharmEssor better personalize the contents, banner, and promotion that you and other users may see on this site. PharmEssor does not retrieve any information from your personal computer and will not disclose any of your personally identifiable information except when PharmEssor has your permission or under special circumstances, such as when PharmEssor believes in good faith that the law requires it. PharmEssor may disclose account information in special cases when it has reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who PharmEssor believes is in violation of PharmEssor's rights.

9 - Linking to Other Sites

Please remember that when you use a link to go from groupeproxim.ca to another website, this Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including any site that has a link on groupeproxim.ca, is subject to the rules and policies of that site. We encourage you to read the rules and policies of the sites you visit to further understand their procedures for collecting, using, and disclosing personal information.

10 - Risk Related to Internet

We will protect personally identifiable information stored on the site's servers from unauthorized access using commercially available computer security products (e.g., firewalls), as well as carefully developed security procedures and practices. Although we use recognized industry safeguards to protect customer personal information from unauthorized access, loss, misuse and unauthorized alteration and every effort is taken to ensure that no one else will see or obtain your personal data, complete confidentiality and security is not yet guaranteed over the Internet. Internet use and communication is subject to interception, loss and alteration. You acknowledge and agree that PharmEssor shall not be responsible for any damages you may suffer as a result of the transmission of confidential or sensitive information over the Internet, and that any and all communications will be at your own risk.

11 - Customer Service and Recourse

If you have any questions about this Privacy and Confidentiality Notice, our information handling practices, or any other aspects of your privacy and the security of information, please send an email to compliance@mckesson.ca.

12 - Updates

We retain the flexibility to update this Privacy and Confidentiality Notice. PharmEssor will not apply changes to this policy retroactively to information PharmEssor has previously collected.