STI Privacy Policy

STI Technologies Limited (“STI”), through its programs and Services, believes that the protection of personal privacy is a fundamental value.  This is particularly true of sensitive personal health and medical information.  STI complies with all Canadian federal and provincial laws respecting privacy, including the Personal Information Protection and Electronic Documents Act of Canada (PIPEDA).  A basic principle of STI’s privacy policy is that STI does not  collect personal information about patients unless it has obtained the express, informed consent of those patients.  This privacy policy summarizes the types of personal information that STI may collect and how STI might use and disclose this information (“Privacy Policy”). STI does not use or disclose the personal information of any patient except as provided herein or permitted by federal or provincial law,  (See “Exceptional Circumstances,” below).

IN CONSIDERATION FOR THE PROVISION OF THE SERVICES, AS DEFINED BELOW, YOU AGREE TO COMPLY WITH THIS PRIVACY POLICY AND, WHERE APPLICABLE, THE INNOVICARES TERMS AND CONDITIONS OF USE (https://innovicares.ca/en/terms). BY USING THE SERVICES, OR BY CHOOSING TO PROVIDE PERSONAL INFORMATION TO STI, NAMELY THROUGH COMPLETING AND SUBMITTING YOUR REGISTRATION FORM, YOU EXPRESSLY CONSENT TO THE COLLECTION, USE, RETENTION AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED HEREIN. PLEASE NOTE THAT Your continued access to and/or use of the Services, constitutes your CONTINUED acceptance of, and agreement to be legally bound by, this Privacy Policy, as IT MAY BE revised.  Please periodically review this Privacy Policy so that you know what Personal Information we collect, how we use it, and with whom we may share it. 

Definitions:  STI uses the following definitions in this Privacy Policy:

STI’s Business: STI provides pharmaceutical marketing solutions that benefit Patients, Providers and manufacturers. 

Websites: This includes, but is not limited to innoviCares.ca and smartsti.com

Services: This includes, but not limited to the features of the Websites, and STI’s Business of offering programs to Patients, Providers and Prescribers which allow broader access to and greater choice of medications and medical devices.

STI Card: A payment card, which may be used by a Patient to pay for some or all of a medication or medical device.

Anonymous Information: Factual or subjective information which cannot reasonably be connected to an identifiable individual.  Examples of anonymous information include age or gender when they cannot be associated with any particular individual; prescribing habits of physicians in aggregate; and the location of a pharmacy where an STI Card was redeemed.

Personal Information: Factual or subjective information regarding an identifiable individual.  Examples include: your name, age, gender, date of birth, medical records, telephone number, home address or email address, or STI Card Client ID (“UCI”) information of an identifiable individual. 

Collect or Collection: The gathering of information, especially Personal Information.

Consent:  Permission given by an individual for STI to collect, retain, use, or disclose their Personal Information.  Express consent occurs when individuals expressly give permission, orally or in writing.

Disclose or Disclosure:  Sharing information (both Personal Information and Anonymous Information) collected or retained by STI with people or organizations within or outside of STI, as described herein.

Exceptional Circumstances: Those circumstances in which PIPEDA and/or provincial laws permit the collection, use, or disclosure of Personal Information without the permission of the individual.  PIPEDA and provincial laws provide that in certain circumstances Personal Information can be collected, used, or disclosed without the knowledge and express consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent. Other examples include: to investigate security breaches or cooperate with government authorities pursuant to a legal matter; to a body responsible by law for the prevention, detection or repression of a crime or statutory offence; or where  the individual is a minor, seriously ill, or mentally incapacitated.

Patient: A person who signs up for the Services or receives one or more STI Cards.

Prescriber: A health care professional, such as a doctor or physician who can advise and authorize the use of a medicine or treatment for a Patient.

Provider:  A health-care professional involved in the distribution or redemption of an STI Card, such as a pharmacist or pharmacy technician.  Providers can also be Prescribers.

Retention:  The storing or holding information whether by physical means (such as documents) or electronic means (such as computer databases, servers or other files).

Use:  Handling or treating information internally within STI, as well as externally with STI’s claims adjudicators or pharmaceutical companies and manufacturers, as set forth herein.  Examples of use of Personal Information is to communicate with the Patient or their Provider; or providing information about an individual’s activities to employees of STI or their Provider for the purpose of helping that individual to use the Services.

 

STI and the Personal Information of Patients

I- Consent

Whenever STI intends to collect, retain, use or disclose Patient Personal Information, it obtains the Patient’s express consent.  This means that STI makes sure that the Patient has been informed of the precise and limited purpose for which the Personal Information is collected, retained, used, or disclosed and that the Patient has expressly consented to that collection, retention, use, or disclosure. You hereby expressly consent to the collection, retention, use and disclosure of your Personal Information as described herein.

II- Collection

The Personal Information STI may collect will depend on the specific Services you request from STI. STI may collect your Personal Information and information about medication, medical devices or health products that you use, your gender, your email address, the benefits and medications that you obtained through using the Services, the name and address of the pharmacy that provided benefits and medications to you as part of the Services, as well as the total value and quantity of medication that you obtained, or other Personal Information that we may specify at the time of the collection and which you consent to the collection of.

By registering for programs, and  presenting an STI Card to a pharmacy, you expressly consent to STI  collecting, using and disclosing your Personal Information as described herein.

III- Retention

You expressly consent to STI retaining your  Personal Information for a period of 10 years or according to STI’s information retention policy.

IV- Use

STI only uses your Personal Information for the purposes for which the consent was given, as described herein.

You hereby expressly consent to STI using your Personal Information,  for the purpose of delivering the Services to you, managing the Services, conducting surveys, notifying you of additional services that STI may offer, processing payments for medications, goods and services related to the provision of the Services, establishing and maintaining communication with you, contacting you to introduce new benefits available as part of the Services, assisting us to comply with all regulatory requirements, and complying generally with the law.

You hereby expressly consent to STI using Anonymous Information that it has collected to prepare reports containing Anonymous Information only for disclosure to third parties, including government, pharmaceutical companies, pharmacists, drug manufacturers and others involved in health care. If you provide Personal Information in an e-mail to STI to ask a question or make a comment, STI will provide that Personal Information only to STI employees who are involved in answering your question or processing your comment.  To the extent possible, the individual to whom your e-mail is assigned will try to obtain an answer or process your comment in a way which does not reveal your Personal Information to other STI employees.  The Personal Information you provide will not be disclosed to third parties unless STI has obtained your express consent or STI is required by law to reveal it due to exceptional circumstances , as described herein. 

NOTE re STI’s adjudicator:  STI, in common with almost all pharmacies and medical insurance plans, uses an electronic services provider, called an adjudicator, to process the redemption of the STI Card.  In order for the adjudicator to validate the Patient’s profile and STI Card UCI, the  pharmacy must send the adjudicator Personal Information about the Patient. Note: The Personal Information sent by the pharmacy is the data contained in your patient profile on the pharmacy’s computer system and is not the Personal Information you have provided to STI. The adjudicator therefore retains Personal Information of the Patient the pharmacy has provided. The Personal Information is then sent to STI  from the adjudicator. STI renders the Personal Information anonymous prior to retaining it. 

How does STI use the information it collects?  STI uses the Personal Information that it collects with the express consent of the Patient for the purposes only for which it was provided and the Services to be rendered.  STI may use your Anonymous Information, to provide reports to the pharmaceutical company whose  medication or medical device was obtained through the Services, for example, STI might provide a report informing the reader about the average age of people using a particular medication or how many of those people are male or female. Since you have provided express consent to collect your Personal Information, STI may communicate with you to provide information on new Services being offered by STI or changes to existing Services.

V- Disclosure

STI only discloses Personal Information to third parties, such as Prescribers, Providers, and claims adjudicators, as described herein and only where the Patients have expressly consented to such disclosure, or as permitted by law.

You hereby expressly consent to STI disclosing your Personal Information to its affiliated companies, Prescribers, Providers and claims adjudicators as indicated herein.

You hereby expressly consent to STI disclosing Anonymous Information that it has collected to to prepare reports containing Anonymous Information only for disclosure to third parties, including government, pharmaceutical companies, pharmacists, drug manufacturers and others involved in health care.

VI- STI and the Personal Information of Prescribers

The information that STI collects through the use of the Services does not include any Personal Information of Prescribers.  No Prescriber’s name, address, or any other Personal Information is submitted to STI through the claim adjudication process described above.

VII- STI and Anonymous Information

STI uses Anonymous Information it has collected for its own internal analyses of the use of the Services.

STI also prepares reports to disclose to third parties, including government, pharmaceutical companies, Prescribers, Providers and others involved in health care.  Those reports are based on Anonymous Information, usually in aggregate form, and do not disclose any Personal Information unless express consent has been obtained.  For example, STI may provide to its pharmaceutical and other clients reports about the timing and geographic distribution of the use of the Services at pharmacies.  Those reports may also include information about the gender and age range of patients using the Services.  Because it is not possible to associate the age range or gender with any particular individual, such information is considered Anonymous Information.  For example, it may be reported that an STI Card for medication X was redeemed at a particular pharmacy on a particular date by a patient who is male and is in the age range 10-20.  STI may also provide reports which show how many times the Services were used at a pharmacy in a certain geographic area, (provinces, cities or FSA (Forward Sorting Area: the first three characters of a postal code), by one or more patients with a particular age range and gender.  Because such information does not reveal any identifying information, such information is considered Anonymous Information.  STI may, however, provide reports to the parties described above that contain Personal Information about an identifiable individual if STI has obtained the express consent of the Patient to use that information for that purpose. For example, STI may provide a report to a Prescriber who is tracking the adherence of patients taking specific medications.

VIII- Protection of your Personal Information

The security of your Personal Information is important to STI. STI protects your Personal Information by maintaining physical, organizational and technological safeguards (appropriate to the sensitivity of such information) and designed to protect against unauthorized  use, disclosure or access of the Personal Information STI collects. Personal Information may only be accessed by persons within STI, or its third party service providers, who require such access to provide you with the Services indicated above.  Personal Information collected is maintained with the source of the information at the STI datacentre in Halifax, Nova Scotia.  

Although STI has taken reasonable and prudent measures to protect its computer systems and any Personal Information that it has collected from unauthorized use, access, disclosure, misuse, alteration or destruction, no security measures can provide absolute protection. As such, STI cannot guarantee the security of your Personal Information, and STI is not responsible for unauthorized use, access, disclosure, misuse, alteration or destruction your Personal Information.

IX- Web site privacy policy

STI does not collect Personal Information or browsing history about visitors to its web sites through the use of browser cookies.

X- Access and Rectification

You have a right to request access to your Personal Information stored at the STI datacentre in Halifax, Nova Scotia and to request a correction to it if you believe it is inaccurate. If you have submitted Personal Information to STI and would like to have access to it, or if you would like to have it removed or corrected, please contact us at This email address is being protected from spambots. You need JavaScript enabled to view it. .  STI will use reasonable efforts to comply with your request; however, in some cases STI may not be able to allow you to access certain Personal Information in certain circumstances, for example if it contains Personal Information of other persons, or for legal reasons. In such cases, on your request, STI will provide you with a reasonable explanation of why it is not possible to grant access to your Personal Information.

XI- Other Important Information

The STI website may contain links to other third party websites. STI does not endorse or otherwise accept responsibility for the content or privacy policies of those sites. Other websites may collect and treat information that they collect differently, so STI encourages you to carefully read and review the privacy policy for each website you visit.

STI reserves the right to modify this Privacy Policy at any time. STI will promptly reflect any such modifications to this Privacy Policy on its website at www.smartsti.com/privacy. Your continued access to and/or use of the Services, or Websites after any such changes constitutes your acceptance of, and agreement to be legally bound by, this Privacy Policy, as revised.  Please periodically review this Privacy Policy so that you know what Personal Information we collect, how we use it, and with whom we may share it. 

How to Contact STI

If you have any questions regarding this Privacy Policy, any Personal Information you have submitted to STI, or if you would like to:

• access Personal Information that you have already provided to STI so that you can correct or update it, or request that it be deleted; or
• report any violation of this Privacy Policy;

Please advise STI by contacting its Privacy Officer by writing to Privacy Officer, STI, 36 Solutions Dr, Suite 360, Halifax, NS, B3S 1N2 or This email address is being protected from spambots. You need JavaScript enabled to view it. . You may also call STI at  1.877.790.1991.