This privacy policy (hereinafter the “Policy“) describes PROxy Network’s practices regarding personally identifiable data and information (“Personal Information“). By using our website, you agree to the terms of this Policy.

Introduction

The PROxy Network controls the website, and all content and materials on the website are owned by us unless otherwise noted and are protected by copyright laws.

The protection of Personal Information is important to the PROxy Network and we make every effort to ensure that it is protected. This policy describes how we collect, use and protect Personal Information when you participate in one of our studies. This policy also explains how you can verify the accuracy of the Personal Information you have provided to us and make corrections.

We also demonstrate our commitment to your privacy by complying with privacy laws and regulations, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Act Respecting the Protection of Personal Information in the Private Sector (Quebec).

Use of Cookies

This section is intended for all users of the website, whether or not they are participating in our studies.

Cookies are small files sent to your web browser and stored on your computer’s hard drive. Cookies assign a random and unique number to your computer and store certain information about your online browsing, IP address, operating system, screen settings, browser type, etc.

When you visit our site, participate in our surveys, log in to your Participant Portal or Pharmacist Portal of the PROxy Network, you consent to the installation of cookies and other similar technologies and to the collection of information on the computing devices (computer, tablet, phone, etc.) you use while visiting our website and portals. No Personal Information is stored on the cookies we use.

These technologies are used for quality assurance purposes to provide you with a good user experience. Cookies allow us to collect information making it easier for users to navigate our sites and to continually improve the layout and functionality of our sites, and they help us display content that is relevant to the user based on language, region, previous pages visited on our site, etc. 

You can set your web browser to notify you when you receive a request to set cookies or to allow your browser to reject cookies entirely. You can delete files that contain cookies; these files are saved in your web browser. However, deleting them may prevent you from completing our online surveys.

Definition

This section is for the participants of our studies.

• “Collection” means the act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, and by any means.

• “Sponsor” means the person or organization that has mandated the PROxy Network to performed the current study.

• “Consent” means voluntary agreement to the collection, use and disclosure of Personal Information for specific purposes. Consent may be express or implied and may be given directly by the individual or indirectly by an authorized person. Express consent may be given verbally, electronically or in writing, but is always unequivocal and does not require any inference on the part of PROxy Network. Implied consent may be reasonably inferred from an individual’s action or inaction.

• “Disclosure” means the transmission of Personal Information to Sponsor.

• “Interviewer” means a PROxy Network employee who communicates with the participant.

• “Personal Information” means any information that identifies you. This information includes, but is not limited to, your first and last name, mailing address, telephone number(s), e-mail address and, in some cases, your opinions and preferences.

• “Demographic Information” means information that will be collected by the PROxy Network and disclosed to Sponsor. This information may be sensitive and does not identify you personally. This information is used to characterize the demographic profile of study participants. Without limiting the generality of the foregoing, this information may include your age, gender, ethnicity, language preference and employment status.

• “Information“: refers collectively to Personal and Demographic Information, as well as any other information or data collected for the purpose of the study.

• “Participant” means an individual recruited by a pharmacist, member of the PROxy Network, who has agreed to participate in a PROxy Network study. These individuals provide Personal Information to the PROxy Network for the purpose of a given study.

• “Member Pharmacist” means a pharmacist who is licensed to practice in Quebec, who is an active member of the Ordre des Pharmaciens du Québec and who has agreed to participate in the PROxy Network in order to become a member.

• “Use” means the processing, handling and management of Personal Information by PROxy Network employees or within the organization, or by a third party engaged by PROxy Network.

Scope and Application

The scope and application of the PROxy Network’s privacy policy are as follows:

• The PROxy Network Privacy Policy also applies to its subsidiary, PeriPharm Inc.

• The PROxy Network Privacy Policy applies to Personal Information that is collected, used or disclosed by the PROxy Network in the course of research and commercial activities.

• PROxy Network’s Privacy Policy applies to the management of Personal Information, whether in verbal, electronic or written form.

• The PROxy Network Privacy Policy does not impose any restrictions on the collection, use or disclosure by the PROxy Network of the following information:

4.4.1. Demographic Information ;

4.4.2. Publicly available information, by country.

Collection of Information

• Information collected: In the course of our studies, we will collect Personal Information and Demographic Information. We may also collect sensitive information, including, but not limited to, health-related information (illness, health status, lifestyle habits and treatment). We will never ask you to disclose information whose loss, misuse or disclosure to an unauthorized person could be considered an economic crime, such as your credit card number, social security number, bank account information, health insurance number or driver’s license number.

• Information Collection Process: We will always collect your Personal Information by fair and lawful means. We collect your Personal Information when you authorize us to do so or as permitted by law. We obtain this Information directly from you when you participate in our studies based on your responses to the questionnaires associated with the studies. Personal Information will never be used for direct marketing of products or services to identifiable individuals.

• Use of Information Collected: When you decide to participate in a study with the PROxy Network, we will explain to you the purposes for which we are using your Information and ensure that we have your Consent before we use that Information.

We collect your Information for the following purposes:

• to conduct research of a qualitative or quantitative nature on behalf of our Sponsors, which consist of corporations, pharmaceutical companies and government institutions;
• to meet regulatory and legal requirements;

In this context, we may use your Personal Information for any of the following purposes:

• to conduct a questionnaire study;
• to validate the answers you provided in a questionnaire for a study we recently conducted;
• to manage the financial compensation following the responses to the questionnaires;
• to update your Personal Information and ensure the accuracy of the data in our records;
• to provide the support you have requested and answer your questions;
• to provide you with general information about the PROxy Network and our services;
• to send you important information regarding your participation and any changes to the terms and conditions governing your participation in a PROxy Network study;
• to verify the integrity of the information submitted;
• to detect and prevent violations of our terms;
• for any other reason for which you have given your permission.

Data collected through the PROxy Network is reported to Sponsors in aggregate (or grouped) form and responses are not associated with any specific individual. In other words, we combine your responses with those of all other study participants and report the responses in aggregate form (e.g., group average). If we were to use personally identifiable Information, we would obtain your express consent before disclosing such Information.

• Disclosure of Information: The PROxy Network will not share your Personal Information with third parties without notifying you, unless required by law or unless the PROxy Network has obtained your consent. The only exceptions under which we may disclose your Personal Information or survey responses to third parties are the following:

• When you consent to the disclosure of your identifying information and responses to a third party for a specific purpose;
• In rare cases, information may be disclosed in response to judicial or governmental subpoenas, warrants or orders, or other legal or regulatory requirements;
• When we believe that disclosure is necessary or appropriate to prevent physical harm or financial loss in connection with suspected or actual illegal activity.

The PROxy Network may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including to meet security requirements or to enforce national laws. The PROxy Network is responsible for appropriate onward transfers of Personal Data to third parties.

• Obtaining Consent: We obtain your Consent explicitly through the use of a consent form that you must sign in all cases before we can use and disclose your Information to our Sponsors for the purposes of the studies for which PROxy Network has been commissioned. We will obtain your Consent for each study in which you participate, if you participate in more than one. Your Information is collected through our web portal and through questionnaires. You must complete the questionnaires yourself and by adhering to this Policy, you agree to complete the forms honestly and according to your personal circumstances. If one of the PROxy Network members contacts you to conduct a telephone discussion, the interview may be recorded and other PROxy Network employees may listen to the conversation to complete notes for training or research evaluation purposes. In order to protect your privacy, only your first name will be used during the discussions. You may refuse to participate in interviews that are recorded or listened to by others.

• Participation in PROxy Network studies: You are always free to decide whether or not to participate in a study, whether or not to answer certain questions, and to end your participation at any time. As a PROxy Network participant, you will be asked to complete our questionnaires. For some studies where multiple questionnaires are due at certain times, you will receive an email reminder that questionnaires must be completed by the end of a specific period. At that time, log in directly to the PROxy Network participant portal to complete your surveys. If you wish to terminate your participation as a PROxy Network study participant, you may, at any time, click on the unsubscribe link located in your participant portal or send an email to info@periproxy.com with the word “unsubscribe” in your message. This way, you will no longer receive reminders to complete the study questionnaires. Of course, if you decide to rejoin the Network at a later date, you can reactivate your account at any time.

• Access to Information: Upon your written request, we will make available to you Information about you that we have collected, used or disclosed to the extent permitted or required by law. This Information will be presented to you in a form that is generally understandable and will be accompanied by a definition of abbreviations and codes. To access the Information we hold about you, you must send us a written request to the email or postal address found later in this policy. When we receive a request for access to information, we will endeavour to provide the requested Information within 30 days. This includes requests for Information about the individual that we hold and control, how we use it and to whom it has been disclosed, if at all. An employee of the PROxy Network will contact you to validate your identity. The PROxy Network reserves the right not to transmit Information if it has concerns about the security of the transmission or the identity of the person requesting the Information.

• Security measures to protect Personal Information: The security of Personal Information is important to us. As such, we have put in place physical, administrative, electronic, contractual and technological procedures that we believe are reasonable and appropriate to protect the security of the Personal Information we have collected about you. The only employees who have access to this Information are those who need it to perform their jobs and are authorized by the PROxy Network. We use firewall technology to prevent electronic intrusion and we use SSL certificates to ensure the confidentiality of information collected by our web applications. Authorized employees can only access your Personal Information, including your email address, using secure logins and passwords within our networks.

Changes to the Policy

We may change this Privacy Policy at any time without notice. Therefore, we encourage you to regularly review it to stay informed about how we handle personal information.

This version was update on April 11, 2023.