Privacy Policy
This Privacy Policy was updated on September 5th 2021.
This Privacy Policy sets forth how 12331845 Canada Inc., owner of the platform Pill0 (the terms “Pill0,” “we,” “us” or “our” in this Privacy Policy shall include any of 12331845 Canada Inc., its directors, officers, shareholders, employees or other representatives) collects, uses, discloses and protects the Personal Information of any user (the “User,” “you,” “your,” or “yours”) of the services offered by Pill0. You may access our services through the Website provided by Pill0 in the manner described in Pill0’s Terms and Conditions of Use (the “Terms of Use”).
Pill0 is a data-driven personalized female healthcare information platform. Pill0 provides relevant information to women based on their health history and based on crowdsourced information which allows registered members to share information and experiences about their medical experiences with contraceptives through organized surveys that get analyzed into general and more specified insights. Our proprietary algorithm identifies contraceptive options based on their typical predicted side effect profile and medical history (the “Services”). Pill0 does not, in any way whatsoever, provide medical advice to its users and does not intend to do so.
We value your privacy, and keeping your data safe is our priority. We have created this Privacy Policy to inform you of our privacy practices. This Privacy Policy is designed to comply with Canadian federal and provincial privacy laws. In the event of a conflict between this Privacy Policy and the Terms of Use, the Terms of Use shall prevail. Capitalized terms not otherwise defined herein shall have the meaning given to them in the Terms of Use.
1. Scope of the Privacy Policy
This Privacy Policy applies to personal information in Pill0’s possession or under its control, including information that Pill0 may exchange with a third party for storage or processing purposes. This Policy does not apply to Pill0’s employees’ or suppliers’ personal information.
2. Acceptance
Use of Pill0’s Website is subject to your compliance with its Terms of Use and this Privacy Policy. By accessing and using this Website, you agree to be bound by the terms contained in these documents. If you do not agree to be bound by these terms, please do not access or use our Website’s features.
Please note that this Privacy Policy applies only to our Website and does not apply to Websites of third-party companies or organizations to which our Website may be linked. Pill0 does not endorse and is not responsible for these linked Websites.
3. Amendments to the Privacy Policy
We reserve the right to amend this Privacy Policy at any time. In the event of any such changes, we will notice you of the specific changes. Your continued use of our Services following the posting of changes to this Privacy Policy constitutes acceptance of those changes.
4. Consent
We would like your consent to collect, use and disclose your personal information for the purposes and in the manner described herein, including to contact you and provide you with promotional and/or informational communications. Your consent must be clear, free and enlightened. Depending on the nature and sensitivity of your personal information, your consent can be expressed (it being understood that such consent may be given electronically) or implied (such as when you provide information voluntarily). Generally, we will seek your consent at the time of collection, except when required or otherwise authorized by law.
You have the choice simply not to submit any personal information to us; however, this may limit our ability to serve you as it may, for example, prevent us from providing you with the most relevant information.
We may share personal information you provide for the purpose detailed in sections 6 and 7 below. You may choose to limit how we use your personal information by not allowing us to share such information with third parties by e-mailing us at the contact link below. Unless informed otherwise by you, we will share your information in the manner and to the partners listed in section 6 and 7.
Your consent can be withdrawn at any time, subject to legal and contractual restrictions and reasonable notice. Please note that if you choose to withdraw your consent, we may not be able to provide you with our Services.
In respect of requests not to receive promotional communications from us, please be sure to include your full name, address, telephone number and any e-mail address you used when you signed up on the Website. It may take up to two (2) weeks to process your request, during which period you may continue to receive communications from Pill0. If you prefer not to receive promotional information from Pill0, please use the unsubscribe link provided in promotional emails.
5. What information do we collect about you?
We may collect different types of data and information from our Users:
1. The first type of information is non-identifiable and anonymous information. We are not aware of the identity of the User from which we have collected the Non-Personal Information. Non-personal information is any unconcealed information which is available to us while Users are using the Service. Non-personal information which is being gathered consists of technical information and behavioral information (e.g the browser type and version, device type).
2. The second type of information is individually identifiable information. This information may identify an individual or may be of a private and/or sensitive nature. Personal information which is being gathered consists of any personal details provided consciously and voluntarily by the User. The Personal information is collected from the details the Users provide when Users wish to contact us or register as a member to the Service, which requires Users to complete a comprehensive registration survey containing the personal and medical details of the User. Types of Personal information that Users may submit include, among others:
Year of birth
Country and province (state) of residence;
(This allows us to identify medications available in your area)E-mail address;
Elements of your medical history and lifestyle which are relevant to providing you the services we provide, as detailed below;
The password associated with a User Account, if applicable;
Language of choice for the use of our Platform;
IP Address; and
Other information you voluntarily share with us.
5.1 Sensitive personal information
At Pill0, we do not take a one-size-fits-all approach. We want to ensure you receive high-quality services tailored to your needs. The information we collect may include information about your health and lifestyle, including past, previous and current experiences and conditions such as hormonal information and other phenotype information. We will process any sensitive personal information with care and in accordance with applicable law and as described in this Privacy Policy.
Medical information. We may process data concerning your health which may include past, current or future physical or mental health status. This may include information about your past medical history, current conditions or other information that may be required to assess your health status. We collect this information when you fill in our survey.
Other sensitive personal information. We may ask you to provide us details around your lifestyle choices, habits or other circumstances (i.e. smoking habits, sex life, etc.) to ensure we have all relevant information to provide you with accurate information.
We don’t collect any sensitive personal information about you (including, but not limited to medical information) except when we have your specific consent.
6. How do we use your personal information ?
Pill0 may use your personal information for the implementation and proper operation of our Services, which includes, but is not limited to:
identify you as a user of our Website and associate you with a User Account, if applicable;
help us better understand your needs and provide high-quality services;
assess the typical side-effects of various contraceptive methods to ensure we provide you with the right information according to your personal needs;
send you marketing communications via e-mail when you agree to be contacted about our products and services;
share your information with our trusted parties, subject to your consent and when necessary for service-related or other purposes;
use your personal information to contribute to building our database with the intent of improving our Services, while maintaining all data anonymous and de-identified;
send you service-related communications via e-mail;
continuously improve our Services;
prevent errors and fraud;
conduct research on contraceptive secondary effects
meeting legal requirements.
We may also use your information to compile anonymous datasets, compile statistics, and detect trends discovered through our Website’s aggregate use by Users. These set of deidentified and anonymized data may be shared or sold to third parties however, we will never share or sell your personal information to any third parties.
Your personal information shall not be used for purposes other than those described above, except with your consent or as required or authorized by law.
7. How do we share your personal information ?
We recognize that, except in the cases and under the conditions described below, the disclosure of your personal information to a third party requires your consent. We may however use or share aggregate de-identified data to third parties, which will contain no identifying information.
Access to your personal information within Pill0 does not require your consent but is strictly limited to the persons for whom the information is necessary for the performance of their functions and duties. In the event of a change of corporate control of Pill0, the new owner and their employees shall have access to the information on a need-to-know basis.
Pill0 does not share personal data with any public databases without explicit permission being granted to do so. Your personal information may be shared with the following partners:
with agents, representatives, mandataries, consultants, data processors, service providers and other parties for whom such information is necessary for the course of Pill0’s activities or to assist Pill0 in the administration of the business relationship (assistance with promotions, provision of technical support, payment gateways, transaction processors, etc.);
with qualified research collaborators. In that case only de-identified data will be shared.
We will then take reasonable steps to ensure that they protect your shared personal information. Please note that if the third party to whom Pill0 discloses your personal information is located in a foreign jurisdiction, local laws may otherwise allow access to your personal information by third parties without your consent. Pill0 will however ensure that this foreign jurisdiction has a comparable level of protection of personal information than Canada.
We may also disclose your personal information without your consent if required or authorized by law.
Whenever Pill0 can or must communicate your personal information, Pill0 will endeavor not to communicate any more personal information than is necessary in the circumstances.
8. How do we keep your personal information secure and accurate?
We take our IT security seriously and ensure we have the appropriate administrative, physical, technical and organizational measures in place to keep your personal information safe. We use the following methods to ensure your personal information is kept safe and confidential: restricting access, encryption, secure cloud storage, etc.
8.1 Data storage & security
We use account information in a password-protected environment and host your personal information in a secure cloud environment. We maintain a high level of data protection via safeguards such as data backup, audit controls, access controls, and data encryption. We use industry-standard TLS 1.2 encryption to enhance the security of electronic data transmissions.
8.2 Data access & disclosure
At Pill0, we restrict access to personal information to only those staff who need to see this information staff and suppliers who need to access this information are subject to strict contractual confidentiality obligations.
Pill0 will adhere to all applicable regulatory requirements to the extent that it has access to or otherwise stores, processes or transmits personal information. We evaluate these safeguards regularly to help minimize risks from new security threats as they become known. However, as it is the case with all Websites, we are unfortunately unable to guarantee security for data collected through our Website (i.e., cookies installed by alternate websites you may visit).
We take reasonable steps to ensure that the personal information we have collected is accurate and complete. However, it is your responsibility to inform us of any changes to your personal information which may occur during the course of our business relationship. We will, upon request, inform you of the existence, use, and disclosure to third parties of your personal information and give you access to said information.
9. How long do we store your personal information for?
We continually review our information collection, data retention, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. We store your personal information for no longer than is necessary, and to ensure we deliver our services smoothly, we provide you with our services at the highest level and contribute to the medical community for research purposes.
10. External links
Our Website may contain links to other external Websites. When you use these links, you leave our Website, and Pill0 has no control over external Websites. Accordingly, Pill0 assumes no responsibility for the protection and privacy of any personal information you provide while visiting such Websites, and this Privacy Policy does not govern such Websites.
11. Phishing
Identity theft and the practice currently known as “phishing” are of great concern to Pill0. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or personal identification numbers in an e-mail or a non-secure or unsolicited telephone communication. We suggest you not respond to and promptly report any e-mail or telephone communication purporting to be from Pill0 in which such information is collected.
12. Requests for access or rectification
Questions or concerns regarding this Privacy Policy or the collection, use and disclosure of your personal information, including requests for access or rectification, should be made in writing to :
Head Office: Box 209, Colborne, Ontario, Canada, K0K 1S0
E-mail: jaclynhearnden@pill0.com
You have the right to consult and obtain a copy of your personal information held by Pill0. You can also request that your personal information be rectified if it is inaccurate, incomplete or equivocal, or if its collection, disclosure or retention is not authorized by law.
Pill0 will respond to every request for access and rectification within 30 days of receiving the written request. If we cannot provide access to or rectify your personal information, we will inform you of the reasons why your request was denied, subject to legal restrictions, and will provide you with any recourse available.
13. International Transfer and applicable law
Your personal information may be transferred outside of the jurisdiction in which you reside and may be stored or otherwise maintained on information systems and devices located in jurisdictions where the privacy laws differ from and, in some cases, may not be as protective as those in your jurisdiction. Pill0 will however ensure that this foreign jurisdiction has a comparable level of protection of personal information than Canada. Your consent to this Privacy Policy followed by the transmission of your personal information to Pill0 represents your agreement to such transfer as well as your acknowledgement and acceptance that the treatment of your personal information will be governed by the laws of the province of Ontario and the applicable federal laws.
14. Compliance with USA privacy regulations
Pill0 is not a Covered Entity or Business Associate of any Covered Entity. Accordingly, any Health Information you provide voluntarily is not protected by the Health Insurance Portability and Accountability Act of 1996, and regulations promulgated there-under, including the Standards for Security and Privacy of Individually Identifiable Health Information at 45 Code of Federal Regulations Parts 160 through 164 (“Privacy and Security Regulations”), as amended from time to time, in addition to the Health Information Technology for Economic and Clinical Health Act, enacted as part of the American Recovery and Reinvestment Act of 2009, Public Law 111-005. Moreover, the Services are not a Medical Device, and thereby is not regulated by the Federal Food, Drug & Cosmetic Act.
15. Canada’s Anti-Spam Law
Pill0 has implemented a series of practices to comply with the consent and unsubscribing provisions for Commercial Electronic Messages (CEMs) in Canada’s Anti-Spam Legislation (CASL). Where CASL requires consent, we ensure that recipients have expressly opted-in or that we have their implied consent to receiving Pill0 communications before they are sent. We provide an obvious, efficient e-mail or web-based mechanism to un-subscribe from e-mail at any time and contacts who make unsubscribe requests will be removed within ten business days.
16. Right to be forgotten
In certain jurisdictions, you have the right to request that Pill0 deletes any personal information collected, subject to certain exceptions. To exercise your right to be forgotten, please contact us by jaclynhearnden@pill0.com. We may take up to 30 days to process your request.
We may still retain personal information to the extent necessary to comply with legal and regulatory requirements (for example, tax and audit purposes). We may also retain personal information to the extent necessary to protect against and prosecute malicious, illegal and fraudulent activity.
17. Cookies and Web-beacons
Your use of our Website allows Pill0 to automatically compile certain information regarding your user profile, which may include the Internet Protocol address (or IP address) of your computer, the operating system you are using, the identity of your Internet service provider, the date and time at which you accessed our Website, the previous Website you visited that provided you with a link to our Website, and the content you viewed and downloaded from our Website.
To this end, our Website uses cookies stored on your device when you visit the Website. Cookies are small data files that a Website stores on your computer’s hard drive or in random access memory when you are viewing the Website. They keep a record of your preferences, making your subsequent visits to the Website more efficient. In certain cases, this information is only kept during the session and is deleted when you close your browser. In other cases, the information is stored on your hard drive and, upon your next visit to the Website, the cookies are used to recall such information.
No personal information is transmitted via cookies. Cookies, by themselves, cannot be used to reveal or discover the identity of the User, and your acceptance of our cookies will not compromise your anonymity while using the Website.
The use of cookies is a common practice adopted by most major Websites to better serve their clients. Most internet browsers are designed to accept cookies, but they can be easily modified to warn you each time a cookie is being sent or block all cookies. This is done through your browser settings; see your browser’s help files for details on how to block cookies, know when you have received cookies, and disable cookies completely. However, you should note that without cookies, some of the Website’s functions will not be available, and you will lose some of the benefits of the Website as, amongst other things, we will not recognize you as a past visitor or a registered user.
18. Update
This Privacy Policy was updated on September 5th 2021.