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Group 88

nuPharma Inc. | Privacy Policy

Introduction

NuPharma Inc. (the “NuPharma” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Policy describes how we collect, use, disclose, and protect the personal information of our Application users (“you”), describes the types of information we may collect from you or that you may provide when you visit the “NuPharma Doctor” software application (our “Application”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by Applicable Law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.

This Privacy Policy applies to information we collect, use, or disclose about our Application users:

  1. on the Application;
  2. in email, text, and other electronic messages between you and the Application or NuPharma representatives;
  3. when you interact with our advertising and applications on third-party Applications and services if those applications or advertising include links to this policy.

The Application may include links to third-party Applications, plug-ins, services, social networks, or websites. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party Application or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party Applications, and we encourage you to read the privacy policy of every website or application you use.

This Privacy Policy does not apply to information collected by:

  1. Any other application operated by NuPharma or any third party (including our affiliates and subsidiaries); or
  2. any third party (including our affiliates and subsidiaries) through any application or content (including advertising) that may link to or be accessible from or on the Application.

Please read this Privacy Policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Application. By accessing or using this Application, you indicate that you understand, accept, and consent to the practices described in this Privacy Policy. This Privacy Policy may change from time to time and will be published on the Application. Your continued use of this Application after we make changes indicates that you accept and consent to those changes, so please check the Privacy Policy periodically for updates. 

Definitions 

In this Privacy Policy, the term “Applicable Laws” includes any applicable federal, provincial or local law as may be appropriate in the context, consumer protection legislation, privacy legislation, statutory law and regulations, common law, the law of equity and any other laws applicable to NuPharma.

Information We Collect About You

We may collect several types of information from and about you, including:

  1. personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information and any other identifier we may use to contact you online or offline (“personal information”);
  2. non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identified individual, demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Application feature;
  3. technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Application, and usage details; and
  4. non-personal details about your Application interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Application (including date and time), services or offerings that you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our client service number.

How We Collect Information About You

We use different methods to collect your information, including through:

  1. direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise;
  2. user contributions, as you may provide information for us to publish or display on public Application areas or transmit to other Application users or third parties;
  3. automated technologies or interactions, as you navigate through our Application. Information collected automatically may include usage details, IP addresses, and information collected through cookies; and
  4. third parties or publicly available sources, for example, our business partners.

Information You Provide to Us

The information we collect directly from you on or through our Application may include:

  1. information that you provide by filling in forms on our Application. This includes information provided at the time of registering to use our Application, subscribing to our service, posting material and/or requesting further services. We may also ask you for information when you report a problem with our Application; 
  2. records and copies of your correspondence (including email addresses), if you contact us;
  3. details of transactions you carry out through our Application and the completion of your transaction. You may be required to provide financial information before completing a transaction through our Application; and
  4. your search queries on the Application.

You may also provide information to be published or displayed (hereinafter, “posted”) on public areas of the Application or transmitted to other users of the Application or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Application with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies

As you navigate through and interact with our Application, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  1. details of your visits to our Application, including traffic data, logs, and other communication data and the resources that you access and use on the Application; and
  2. information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Application and to deliver a better and more personalized service, including by enabling us to:

  1. estimate our audience size and usage patterns;
  2. store information about your preferences, allowing us to customize our Application according to your individual interests;
  3. speed up your searches; and
  4. recognize you when you return to our Application.

The technologies we use for this automatic data collection may include:

  1. Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate settings on your browser. However, if you select this setting you may be unable to access certain parts of our Application. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Application.
  2. Flash Cookies. Certain features of our Application may use locally stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Application. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Tracking Technologies and Advertising.
  3. Web Beacons. Pages of our Application may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit NuPharma, for example, to count users who have visited those pages or for other related Application statistics (for example, recording the popularity of certain Application content and verifying system and server integrity).

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  1. to present our Application and its contents to you;
  2. to provide you with information or services that you request from us;
  3. to carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements;
  4. to fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it;
  5. to notify you about changes to our Application or any services we offer or provide through it;
  6. to improve our Application, services, marketing, and user experiences;
  7. to allow you to participate in interactive features or similar features on our Application;
  8. in any other way we may describe when you provide the information; and
  9. for any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

  1. in accordance with Applicable Law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all NuPharma’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by NuPharma about our users is among the assets transferred;
  2. to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Application improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy;
  3. Payment information contained in payment cards and information related to your purchase will be shared with the financial institution that issued your payment card and our payments processing service provider to verify that the purchase can be completed and for the purposes of authorizing and approving transactions and mitigating fraud;
  4. to fulfill the purpose for which you provide it; 
  5. for any other purpose disclosed by us when you provide the information; and
  6. with your consent.

We may also disclose your personal information:

  1. to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with Applicable Laws; 
  2. to enforce or apply the terms of our client agreement and other agreements, including for billing and collection purposes; and
  3. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of NuPharma, our clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection. 

Transferring Your Personal Information

We may transfer personal information that we collect or that you provide as described in this Privacy Policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Application improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this Privacy Policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this Privacy Policy and Applicable Laws.

By submitting your personal information or engaging with the Application, you consent to this transfer, storage, or processing.

Tracking Technologies and Advertising

You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s Application. If you disable or refuse cookies, please note that some parts of this Application may not be accessible or may not function properly. For more information about tracking technologies, see Information We Collect Through Cookies and Other Automatic Data Collection Technologies.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also access these Applications to learn more about online behavioral advertising and how to stop Applications from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

Data Security

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on secured cloud-based servers hosted by a market-leading service provider. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Application. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained in the Application.

Data Retention

Except as otherwise permitted or required by Applicable Law, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Accessing and Correcting Your Personal Information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law, you have the right to request access to and to correct the personal information that we hold about you.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may 

We may request specific information from you to help us confirm your identity and your right to access and to provide you with the personal information that we hold about you or make your requested changes. Applicable Laws may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in Applicable Law. Examples of such exceptions include:

  1. information protected by solicitor-client privilege;

  2. information that is part of a formal dispute resolution process;

  3. information that is about another individual that would reveal their personal information or confidential commercial information; and

  4. information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact us.

Withdrawing your Consent

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us. Please note that if you withdraw your consent we may not be able to provide you with a particular service. We will explain the impact to you at the time to help you with your decision.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. We include the date the Privacy Policy was last revised at the bottom of the page. You are responsible for periodically visiting our Application and this Privacy Policy to check for any changes.

Get in touch.

Have any questions about the app? Don’t hesitate to reach out. We would happy to answer any questions that you might have.

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