Privacy Policy

Last Updated: August 22nd, 2025

PXC Inc. ("PharmacyXChange", "we", "us" or "our") understands the importance of protecting the personal information of individuals and the importance of securing confidential information of all types. We have created this Privacy Policy (this "Policy") to demonstrate our commitment to protecting your privacy. This Policy explains:

As used in this Policy, "personal information" means any information about an identifiable individual or information that can reasonably be used to identify an individual, whether alone or in combination with other information. Personal information may include, for example, a person's name, home address, telephone number, email address, date of birth, government-issued identification numbers, financial account information, payment card details, billing information, location data, and IP address.

This Policy forms an integral part of, and is subject to, our Terms of Use. Unless otherwise defined in this Policy, all capitalized terms used in this Policy shall have the meanings ascribed to them in our Terms of Use. This Policy sets out the manner in which we may collect, use, disclose and other process personal information from users of the Platform ("you" or "your"). Personal information may be collected directly from you or from third parties who are lawfully permitted to disclose such information to us.

We reserve the right to amend this Policy at any time. Any amendments will be communicated to you either by sending a notice to the email address associated with your user account or by posting an updated version of the Policy on the Platform. The most recent version of this Policy will govern our collection, use, disclosure, retention, and other processing of your personal information. By continuing to access or use the Platform following any changes to this Policy, you acknowledge and agree to be bound by the revised terms. If you do not agree to any amendment, you may cancel your user account at any time. We strongly encourage you to review this Policy periodically to remain informed about our practices regarding your personal information. The "Last Updated" date at the beginning of this Policy reflects the date of the most recent revision.

1. Consent for Personal Information

2. What Personal Information Do We Collect and Why Do We Collect It?

Types of Personal Information and Collection Purposes

We collect and process personal information in accordance with this Privacy Policy. We do not sell, share, or rent your personal information to third parties, except as expressly provided in this Policy or with your consent. The table below outlines the categories of personal information we collect and the purposes for which such information is collected. Please note that we do not knowingly or intentionally collect any personal health information or health information.

Categories of Personal Information Description of the Category Collection Purposes
Registration Data When you create a user account, you will be asked to provide certain information, such as your full name, business address, business phone number, business email address, and pharmacist licence number. We use this information to provide you with access to the Platform.
Photos and Messaging Data If you upload photos or use the messaging function through the Platform, all such photos and messages must relate solely to pharmaceutical products and must not contain any patient-related information. We access your device's camera solely to scan the barcode of a pharmaceutical product and automatically populate the relevant listing information. We do not store any photos. Messaging logs are collected and stored for retention purposes.
Usage Data When you access the Platform, we may automatically collect certain information about your device. For users accessing the web version of the Platform this includes the URL you visited before and after accessing the Platform. For all users of the Platform, we may collect your browser type, IP address, and geolocation. We use this information to: (i) analyze how users browse and interact with the Platform; (ii) monitor, maintain, and improve Platform performance; (iii) detect and prevent tampering or interference; and (iv) conduct internal research on user demographics, interests, and behaviour to better understand, protect, and serve users.
Advertising Data From time to time, we may display advertisements, including promoted listings or sponsored content, provided by us or by our third party advertising partners. In connection with these advertisements, the following categories of personal information may be collected: usage data (as described above) and information regarding your interactions with advertisements. This information is collected to enable the delivery of relevant advertisements, to measure the effectiveness of advertising campaigns, and to prevent fraud or misuse of the advertising services. The collection and use of such information by third party advertisers is governed by their respective privacy policies.
Customer Service Data When you contact us, you may be asked for information that identifies you (such as your name, address, and email address) along with additional information we need to help us promptly respond to your inquiry. We use this information to respond to your inquiry and to understand, troubleshoot, and fix any potential issues with the Platform. We may also retain this information to assist you in the future and to improve our customer service, and product and service offerings.

Additional Collection Purposes

In addition to the collection purposes set out in Section 2.1, we may also collect your personal information for the following general purposes: (i) to help us enforce our Terms of Use; (ii) to evaluate and develop new features, technologies, and improvements to the Platform; (iii) to provide you with system or administrative messages; and (iv) to send you marketing communications, subject to obtaining any consent required under applicable law. We will only send marketing messages where permitted by applicable law, and you can withdraw your consent to receiving such messages at any time by contacting us using the details provided in Section 9.

3. How Do We Collect Your Personal Information?

Direct Interactions

You may provide personal information through the Platform, by email, or through other forms of communication with us.

Automated Technologies or Interactions

As you interact with the Platform, we may automatically collect certain usage data using cookies, mobile device identifiers, and other similar technologies. Cookies are small text files that are placed on your computer or mobile device by your web browser when you visit a website. These files enable the Platform to recognise your device on subsequent visits and to remember information such as your preferences, pages visited, and login details. The use of cookies and similar technologies is common practice and helps to enhance the functionality and efficiency of digital platforms. The Platform utilizes these technologies to optimise your user experience and to ensure the proper functioning of the Platform. Most web browsers provide options to manage, restrict, or block cookies through their settings. Please note, however, that disabling cookies may impact the functionality of certain features of the Platform and may affect your ability to use some services. For more information about cookies, please visit our Cookies Policy.

4. Disclosure of Personal Information

Service Provider Arrangements

Legal

We may disclose your personal information in the following circumstances: (i) to any governmental authority as part of an investigation to determine our compliance with any applicable law, regulation, or rule; (ii) in response to a court order, subpoena, discovery request, or other lawful judicial or administrative process; (iii) as otherwise required by any applicable law, regulation, or rule; and (iv) in good faith, where necessary to protect or defend our rights or property, or those of other users.

5. Your Rights and Access

Privacy Settings

You may manage your privacy settings through your user account. You may modify or remove the information in your user account at any time by logging into your user account and making the desired changes. Please note that, for technical reasons, any modifications or deletions you request may take a short period of time to take effect.

Access

You have the right to access the personal information that we hold about you. You can request from us information about: (i) the personal information we hold about you; (ii) the categories of personal information concerned; (iii) the purposes of the processing; (iv) details of to whom your personal information has been or will be disclosed; (v) the duration for which we retain your personal information; (vi) if we did not collect the information directly from you, information about the source; and (vii) how to lodge a complaint with the appropriate regulatory authority.

Correction of Inaccuracies

You have the right to request the update and correction of inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law, by emailing us at the contact information set out in Section 9. In connection with any such request, we may require certain personal information from you for the purposes of verifying your identity.

6. Security

We employ reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of personal information in our custody and control. It is important to remember that no method of transmitting or storing data is completely secure. You can help prevent unauthorized access to your user account and personal information by selecting and securing your user account password properly and limiting access to your computer, mobile device, and browser.

7. Retention and Deletion

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected or as required by law. Once the information is no longer required, and in accordance with our data retention policies, we will delete, anonymize, or otherwise dispose of personal information in compliance with applicable laws.

8. Third Party Websites and Services

This Policy does not apply to any websites, products, or services provided by third parties. We do not accept any responsibility or liability for the privacy practices of such third parties. We strongly encourage you to review the privacy policies of all third party websites, products, or services before accessing or using them.

9. Contact Us

If you have any questions or concerns about this Policy or our handling of your personal information, please contact us at:

privacy@pharmacyxchange.ca

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