Like you, we at Santé enjoy our privacy. So, we understand that safeguarding your confidentiality and protecting your personal and health information (collectively referred to as ‘Health Information’) is a primary concern. As part of this commitment, Santé has followed Ten Privacy Principles (we don’t know who first created these, but we like them) to govern our actions as they relate to the use of Health Information. The Ten Privacy Principles are as follows:

Principle 1 – Accountability

Santé is responsible for maintaining and protecting any Health Information under our control. In fulfilling this mandate, Santé has designated an individual who is accountable for our compliance with the Ten Privacy Principles.

Principle 2 – Identifying Purposes 

The purposes for which Health Information is collected shall be identified before or at the time the information is collected.

Principle 3 – Consent

The knowledge and consent of the customer is required for the collection, use or disclosure of Health Information except where otherwise required or permitted by law.

Principle 4 – Limiting Collection 

The Health Information collected must be limited to those details necessary for the purposes identified by Santé. Information must be collected by fair and lawful means.

Principle 5 – Limiting Use, Disclosure and Retention

Health Information may only be used or disclosed for the purpose for which it was collected unless the Customer has otherwise consented, or when it is required or permitted by law. Health Information may only be retained for the period of time required to fulfill the purpose for which it was collected.

Principle 6 – Accuracy

Health Information must be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used.

Principle 7 – Safeguarding Health Information

Health Information must be protected by security safeguards that are appropriate to the sensitivity level of the information.

Principle 8 – Openness 

Santé is required to make information available to Customers concerning the policies and practices that apply to the management of their Health Information.

Principle 9 – Customer Access 

Upon request, a Customer shall be informed of the existence, use and disclosure of their information, and shall be given access to it. Customers may verify the accuracy and completeness of their information, and may request that it be amended, if appropriate.

Principle 10 – Handling Customer Complaints and Suggestions 

Customers may direct any questions or enquires with respect to the privacy principles outlined above or about our practices by contacting Santé’s Privacy Officer.

The guidelines below set forth the principles we use in gathering, using, maintaining and protection Health Information you provide us.

The Types of Health Information We Collect

Santé gathers and uses only such information that is necessary for providing our services and fulfilling your orders. It typically includes the following Health Information:

Name, mailing address, e-mail address, telephone numbers, occupation, employment status, referral source, the name of your primary physician and his or her contact information, age, height, weight, sex, date of birth, the existence and types of drug allergies, medications requested, family medical history information, your personal medical history information, details of your existing medications, credit card information (including card type and number, expiry date and name of card holder), banking information (including transit and account numbers) and prescription information. The choice to provide us with Health Information is always yours. However, your decision to withhold particular details may limit the products and services we are able to provide and make it more difficult for us to advise you or suggest appropriate alternatives. If we are unable to accommodate your request based upon the information that has been provided, we may ask for additional details in order to identify other ways to be of assistance. We may also maintain a file containing contact history that is used for customer inquiry purposes.

We may collect anonymous/non-Health Information. Anonymous/non-Health Information is information that cannot be associated with or traced back to a specific individual or business entity.

The Purposes for which we use Health Information

We use your Health Information to communicate with you, enhance your visit to our website, allow processing of your orders and effectively provide the products and services you have requested. We may provide your Health Information to an affiliated company, a licensed pharmacy or to a prescribing physician in order to fulfill your order.

We may use your Health Information to offer additional products and services sold by Santé or one of its affiliates. In the event of a sale of all or substantially all of the assets of Santé, records containing Health Information may be transferred to the purchaser. We will not furnish your Health Information to an outside organization for its use in marketing or solicitation without your prior consent.

We only use your Health Information for the purposes that we have disclosed to you. If for any reason your information is required to fulfill a different purpose, we will notify you and ask you for your consent before we proceed.

In some instances such as a legal proceeding or court order, we may also be required to disclose certain information to authorities. Only the information specifically requested is disclosed and we will take precautions to satisfy ourselves that the authorities who are making the request have legitimate grounds to do so.

There are some situations where we are legally permitted to disclose Health Information such as employing reasonable and legal methods to collect a delinquent account, a medical emergency or suspicion of illegal activities.

We sometimes contract outside organizations to perform specialized services. Our trusted service suppliers may at times be responsible for processing and handling some of the Health Information we have received from you.

When you visit our website, information is not collected that could identify you personally unless you choose to provide it voluntarily. You are welcome to browse our website at any time anonymously and privately without revealing any Health Information about yourself.

Security Measures

We use current technologies and maintain security standards to ensure that your Health Information is protected against unauthorized access, disclosure, inappropriate alteration or misuse. All safety and security measures are also appropriate to the sensitivity level of your information. Electronic client files are kept in a secured environment with restricted access. Paper-based files are stored in restricted access areas.

We manage our server environment appropriately and our firewall infrastructure is strictly adhered to. Our security practices are reviewed periodically and we employ current technologies to assist us in protecting the confidentiality and privacy of your information.

In the course of daily operations, we attempt to restrict access to Health Information to authorized employees who have a legitimate business purpose and reason for accessing it. As a condition of their employment, all employees of Santé are required to sign a confidentiality agreement, abide by the privacy standards we have established and to follow all applicable laws and regulations. Unauthorized access to and/or disclosure of client information by an employee of Santé is strictly prohibited. All employees are expected to maintain the confidentiality of Health Information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.

Accessing and Amending Your Information

Decisions are often made based on the information we have. Therefore, it is important that your Health Information is accurate and complete. As a customer, you have the right to access, verify and amend the information held in your personal and financial files.

To help us keep your Health Information up-to-date, we encourage you to amend inaccuracies and make corrections as often as necessary. Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file(s), we will make the proper changes and provide you with a copy of the corrected information. Where appropriate, we will communicate these changes to other parties who may have unintentionally received incorrect information from us.

If you have any questions or concerns regarding the nature, purpose and consequences of our collection, use, or disclosure of your information, please contact us.

Privacy Officer

Customers may direct any questions or enquires with respect to our practices or your Health Information by contacting our Privacy Officer, as follows:

Santé Bespoke Enterprise Ltd.

Attention: Privacy Officer

Telephone No: 1-833-469-7268

E-Mail: privacy@santebespoke.com

Updating this Policy

Any changes to our privacy policy and information handling practices shall be acknowledged in this policy in a timely manner. We may add, modify or remove portions of this policy when we feel it is appropriate to do so. You may determine when this policy was last updated by referring to the modification date found at the bottom of each of Santé’s privacy policy web pages.

last updated: July 22, 2021