Privacy Policy
Updated September 22nd, 2026
YOUR ACCEPTANCE OF THIS POLICY
Pillexa Inc. and our affiliates ("Pillexa", "we", "us", and "our") respect your privacy and are committed to protecting it.
This policy applies to information we collect, use, or disclose about you on the Pillexa platform (the "Platform"), as further described in our terms of use (our "Terms"), through your correspondence with us, and when you interact with us or our advertising and applications on third-party websites and services. Capitalized terms used but not defined in this policy have the meaning ascribed to them in our Terms.
Please read this policy carefully to understand Pillexa's policies and practices for collecting, processing, and storing your personal information. If you do not agree with our policies and practices, please do not use the Platform.
By accessing or using the Platform, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time. Your continued use of this Platform after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. Moreover, if you provide Pillexa or our service providers and agents with personal information of another individual, you represent that you have all necessary authority or have obtained all necessary consents from such person to enable us to collect, use, and disclose such personal information for the purposes set forth in this policy. If you do not have the necessary authority or consents, please do not provide the personal information of that other individual. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information to the extent required by law.
What is personal information and what is covered by this Policy
Privacy laws 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 an individual.
This policy describes how we collect, use, disclose, maintain, and protect your personal information when you use the Platform.
This Privacy Policy applies to both personal information and, where applicable, personal health information. Personal health information is a subset of personal information. It includes identifying information about an individual’s health status, health services provided, prescriptions, or payment information related to healthcare. When Pillexa acts as an informational service provider or agent in relation to personal health information, we will handle such information in accordance with the applicable federal, provincial or state health privacy legislation. For greater certainty, your personal health information shall not be sold, transferred outside of the specified purposes hereunder, or used or otherwise shared with any third party for the purposes of advertising.
Because Pillexa may assist third parties in the provision of certain health-related products and services, certain provisions of provincial or state level health privacy laws (such as Ontario’s PHIPA, Alberta’s HIA, British Columbia’s PIPA, and Quebec’s Law 25) may apply in addition to the Personal Information Protection and Electronic Documents Act (“PIPEDA”). Where such provincial laws apply, we will comply with the higher standard of protection required.
We will only use your personal information in accordance with this policy or as otherwise permitted or required by applicable law. We take steps to ensure that the personal information we collect about you is adequate, relevant, not excessive, and used for limited purposes.
Third-party websites
The Platform may include links to third-party websites, plug-ins, services, social networks, or applications. 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 website or engage a third-party plugin, please note that we do not control these third-party websites, these third parties have their own privacy policies and we are not responsible or liable for these policies, and we encourage you to read the privacy policy of every website you visit.
INFORMATION WE COLLECT ABOUT YOU
We collect and use several types of information from and about you, including:
Personal information, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, username or other similar identifier, billing and account information, and any other identifier we may use to contact you, as well as information you provide when using our services, including the answers you provide to applicable medical intake questionnaires facilitated through the Platform (an “Intake Questionnaire”), which may include information relating to your health including your age, height, weight, medical history, current medications, and other information required by the applicable medical practitioner (a “Prescriber”);
Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as non-personal 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 feature of the Platform in a way that cannot be used to identify an individual; and
Technical information, including your login information, if any, 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 the Platform, and usage and interaction details.
Information you provide to us
We use different methods to collect your information, including through:
Direct interactions with you where you provide information to us, for example, by completing Intake Questionnaires on the Platform or otherwise corresponding with us or with third party brands (“Brands”), Prescribers, or pharmaceutical providers (“Pharmacies”) on or through the Platform;
Automated technologies or interactions, as you navigate through the Platform. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, or other tracking technologies;
Third parties or publicly available sources, for example, from Brands, Prescribers, or Pharmacies.
How we collect information about you
The information we collect directly from you on or through the Platform may include information that you provide through your use of the Platform, and your search queries or other correspondence made on or through the Platform.
As you navigate through and interact with the Platform, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
Details of your visits to the Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform; and
Information about your computer and internet connection, including your IP address, operating system, and browser type.
We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool (https://youradchoices.ca/en/tools). We may also use this information to monitor your applicable health service or product order requests (“Order Requests”) for compliance with our terms of use.
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. It helps us to improve the Platform and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns, store information about your preferences, speed up your searches, and recognize you when you return to the Platform.
Third Parties
We may also collect information, including personal information, about you from third parties, which we may combine with other information we have collected, including from Brands, Prescribers, and Pharmacies. For example, we may receive a copy of prescriptions issued to you by Prescriber through the Platform so that we can share that back to you, which may occur through your user account hosted on a Brand's website.
Some content or applications on the Platform, including advertisements, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. Excepting any personal health information, they may use this information to provide you with interest-based (behavioural) advertising or other targeted content.
We do not control these third-party tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
In certain circumstances, examples of which are described below, we may disclose your personal information to third parties who may use it for their own purposes and subject to their own privacy policies.
A current list of third-party service providers who may have access to certain types of your Personal Information is as follows:
Aptible – we use Aptible to assist us with cloud infrastructure for the purposes of complying with applicable legislation, including HIPAA/PIPEDA. Aptible’s data practices are governed by the Aptible Privacy Policy, as it may be amended from time to time.
Amazon Web Services – we use AWS to facilitate our services through the provision of cloud infrastructure services. AWS ’s data practices are governed by the AWS Privacy Policy, as it may be amended from time to time.
Cloudflare – we use Cloudflare to enhance the internet performance and security of our services. Cloudflare’s data practices are governed by the Cloudflare Privacy Policy, as it may be amended from time to time.
Datadog – we use datadog for security based services to maintain the privacy, security and observability of our services. Datadog ’s data practices are governed by the Datadog Privacy Policy, as it may be amended from time to time.
GoogleAds / Google Analytics – we use Google Ads to administer certain online marketing campaigns. Google Analytics to help us understand how our customers use the Services. Google may collect your IP address, data related to the device/browser, or other information about your use of our website and may do so using cookies. Google’s data practices are governed by the Google Privacy Policy, as it may be amended from time to time.
Klaviyo – we use Klaviyo to facilitate email marketing campaigns and mail-outs. Klaviyo’s data practices are governed by the Klaviyo Privacy Policy, as it may be amended from time to time.
Meta (Facebook / Instagram) Ads – We use Meta for the purposes of operating social media marketing campaigns, Meta’s data practices are governed by the Meta Privacy Policy, as it may be amended from time to time.
Microsoft Azure – we use Azure for the purposes of cloud infrastructure services. Azure’s data practices are governed by the Microsoft Privacy Policy, as it may be amended from time to time.
PostHog – we use PostHog as a development tool to gain insight into user behaviour and metrics. Posthog’s data practices are governed by the PostHog Privacy Policy, as it may be amended from time to time.
SendGrid/Twilio – we use this platform to assist with customer communication and lifecycle management. SendGrid/Twilio’s data practices are governed by their Privacy Policy, as it may be amended from time to time.
Stripe – we use Stripe as a payment processor to facilitate payment for your products. Stripe’s data practices are governed by the Stripe Privacy Policy, as it may be amended from time to time.
Vouched – we use Vouched for digital identification services. Vouched’s data practices are governed by the Vouched Privacy Policy, as it may be amended from time to time.
Webflow – we use Webflow to assist with our website development and maintenance. Webflow’s data practices are governed by the Webflow Privacy Policy, as it may be amended from time to time.
CONSENT FOR USE OF YOUR INFORMATION
Consent for General Personal Information
We will not use or disclose any of your personal information to anyone except as described in this policy. Except as explicitly specified below, we will obtain your express or implied consent to collect, use, sell or disclose any personal information. You can provide consent orally, in writing, electronically or through an authorized representative. You provide us with implied consent where our purpose for collecting, using or disclosing personal information is necessary for the provision of our services or would be considered obvious or reasonable in the circumstances. Your consent may also be implied where you have received notice and a reasonable opportunity to opt-out of having the personal information used, and you have not provided us with notice of your opting-out, including but not limited to use for mail-outs, marketing, fundraising, or in the event of the sale of our business undertaking.
Consent for Personal Health Information
For non-sensitive personal information, we may rely on implied consent where appropriate. However, for sensitive personal information, including personal health information, we require express, informed consent. Where required by provincial law (e.g., PHIPA in Ontario, HIA in Alberta, Law 25 in Quebec), consent may need to be documented in writing or clearly recorded. You may withdraw consent at any time, subject to legal or contractual restrictions, by contacting our Privacy Officer through the contact details listed below.
Limited Use Without Consent
We may collect, use or disclose your personal information without your consent in the following circumstances:
when permitted or required by law;
in an emergency that threatens an individual's life, health, or personal security;
when the personal information is available from a public source;
when we require legal advice from a lawyer; or
for the purposes of collecting a debt or protection from fraud (with the exception of personal health information);
or other legally established reasons.
HOW WE USE YOUR INFORMATION
We use information, including personal information, that we collect about you or that you provide to us:
To present the Platform and its contents to you and notify you about changes to the Platform or any products or services offered or provided through it;
To fulfill the purposes for which you provided the information or that were described when it was collected, including to enable the review and, if approved, fulfillment of Order Requests by Brands, Prescribers, and Pharmacies, or any other purpose for which you provide it;
To carry out our obligations and enforce our rights arising from any contracts with you or to comply with legal requirements, protect the safety, rights, property, or security of Pillexa or the general public, detect, prevent, or otherwise address fraud, security, or technical issues, and to prevent or stop activity that we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity;
To improve the Platform, products or services, marketing, or customer relationships and experiences, measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you, or monitor, analyze and understand usage and activity trends and for other research, analytical, and statistical purposes; and
For any other purpose with your consent or as permitted by law.
Provided that under no circumstances shall we utilize, transfer or sell any of your personal health information except in strict compliance with all applicable laws, and for greater certainty, shall not be sold, or utilized or transferred to any third party for the purposes of marketing or advertising.
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
To Brands, Prescribers, and Pharmacies for the purposes of reviewing your Order Requests and, if approved, prescribing, filling, and delivering the applicable Products;
To our subsidiaries and affiliates, as applicable;
In accordance with applicable law, to another entity in connection with an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer in which personal information held by Pillexa is among the assets transferred, including during negotiations related to such transactions;
Subject to all restrictions herein related to your personal health information, to advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We may use aggregate information about our users to help advertisers target a specific audience. We may make use of the personal information we have collected from you to enable us to display our advertisers' advertisement to that target audience;
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 Platform 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;
To fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide the information or permitted by law, or with your consent; or
To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law, enforce or apply our terms of use www.pillexa.com/terms-of-use and other agreements, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Pillexa, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer personal information that we collect or that you provide as described in this 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 website improvement and optimization), including to Brands, Prescribers, and Pharmacies, 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.
By providing us with personal information, you acknowledge and agree that such personal information may be transferred to other jurisdictions for processing and storage, including in servers located across Canada and in the United States. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of the jurisdiction of destination may be able to obtain access to your personal information through the laws of the foreign country (e.g., the U.S. Patriot Act or CLOUD Act). We will take contractual and technical measures to ensure that any third-party service providers handling personal health information on our behalf provide privacy and security safeguards equivalent to those required by Canadian federal and provincial health privacy laws. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
DATA SECURITY
The security of your personal information is very important to us. We use reasonable physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions performed by Pillexa will be encrypted using SSL technology. Your personal information that constitutes personal health information is held in a secure environment hosted by an applicable third party cloud service provider in compliance with all applicable laws. In addition to the safeguards already described, when handling any personal health information we apply enhanced protections, including: role-based access controls, user authentication, and audit logging of access to personal health information. We also maintain written policies for responding to privacy breaches involving personal information, including, with respect to any breach concerning personal health information, mandatory reporting to regulators and affected individuals as required by PIPEDA and applicable provincial laws (e.g., PHIPA, HIA, Law 25).
The safety and security of your information also depends on you. You are responsible for keeping your account details confidential and secure.
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 the Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.
In the unlikely event that our system is breached, and any personal information has been compromised, we will notify such local authorities and regulators as may be required within seventy-two (72) hours of the breach and will also use our best efforts to notify you, using the most current contact information that we have on file. We are not responsible for any failure to notify you based on incorrect or outdated contact information.
DATA RETENTION
Except as otherwise permitted or required by applicable law or regulation, 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 purpose without further notice to you or your consent and may sell or otherwise transfer such data to third parties.
With respect to personal health information, provincial or state laws may impose specific retention periods (e.g., in Ontario, at least 10 years after the last entry for adults, or 10 years after a minor turns 18). Where Pillexa is required to retain your personal health information, we will follow these statutory minimums. When records are no longer required, they will be securely destroyed or anonymized in accordance with recognized industry practices.
UNITED STATES/HIPAA AND STATE HEALTH PRIVACY LAW
Status and applicable law. For customers located in the United States, the physicians who provide clinical services are the treating providers and, where applicable, covered entities under the United States Health Insurance Portability and Accountability Act (“HIPAA”). Where we create, receive, maintain, or transmit protected health information on behalf of those providers, we act as a business associate and handle that information in accordance with HIPAA and written business associate agreements. In addition to HIPAA, we comply with applicable state health and consumer privacy laws, including the California Confidentiality of Medical Information Act, the California Consumer Privacy Act as amended, the Washington My Health My Data Act, and the U.S. Federal Trade Commission's Health Breach Notification Rule. Consumer health data of residents of states with applicable consumer health data legislation is also governed by our Consumer Health Data Privacy Policy, available at https://pillexa.com/consumer-health-data-privacy.
Breach notification. Notwithstanding anything set out herein to the contrary, if we become aware of a breach of security affecting your personal information or protected health information, we will notify the applicable authorities and regulators as required by law and without undue delay, and in any event within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals as required by applicable law. Where we act as a business associate, we will notify the applicable covered entity within the period required by our agreement with them.
US consumer rights: If you are a resident of a U.S. state with applicable consumer privacy legislation, you may have the right to: confirm whether we process your personal information and access it; request correction of inaccurate information; request deletion; obtain a portable copy; opt out of the sale or sharing of personal information and of targeted advertising; and not be discriminated against for exercising these rights. We do not sell personal information, and we do not use or disclose personal health information for advertising or marketing. To exercise a right, contact privacy@pillexa.com. We will verify your identity and respond within forty-five (45) days, extendable once where reasonably necessary, and will tell you how to appeal if we decline.
CHILDREN UNDER THE AGE OF 18
No one under age 18 may provide any personal information through or on the Platform without parental or guardian consent. We do not knowingly collect personal information from children under 18 without such consent. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact our Privacy Officer.
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, to correct, and delete the personal information that we hold about you.
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 law 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.
Under PIPEDA, you have the right to access and request correction of your personal information, including personal health information, that we hold. We will respond to such requests within 30 days, unless an extension is permitted by law, and will provide reasons if we refuse access (for example, if disclosure would reveal another person’s information or is subject to legal privilege). Under provincial health laws, you may have additional rights of access or correction, and we will respect those rights where applicable.
We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation.
If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer.
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 our Privacy Officer. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or 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 and to notify you via email of all material changes to this Privacy Policy. We include the date the privacy policy was last revised at the top of the page. You are responsible for periodically visiting the Platform and this privacy policy to check for any changes.
GOVERNING LAW AND CHOICE OF FORUM
These Terms are governed by and to be construed in accordance with the laws of the Province of British Columbia and the federal laws of Canada applicable therein, without giving effect to any choice or conflict of law provision, principle, or rule (whether of the laws of the Province of British Columbia or any other jurisdiction) and notwithstanding your domicile, residence, or physical location.
Any action or proceeding arising out of or relating to the Platform or these Terms must be instituted in the courts of the Province of British Columbia or the Federal Court of Canada, as applicable, and each party irrevocably submits to the exclusive jurisdiction of such courts in any such action or proceeding. You waive all objections to the exercise of jurisdiction over you by such courts and to the venue of such courts.
Notwithstanding the foregoing, nothing in these Terms limits, waives, or restricts any right or remedy available to you under any law of your jurisdiction of residence that cannot lawfully be limited, waived, or restricted by agreement, including consumer protection and health privacy legislation. Nothing in these Terms limits the jurisdiction of any court, regulator, professional college or licensing body, or government authority having jurisdiction over us, over any prescriber or pharmacy providing services in connection with your order, or over the subject matter of these Terms. Where any provision of these Terms conflicts with a mandatory provision of the law of your jurisdiction of residence, that mandatory provision prevails to the extent of the conflict, and the remainder of these Terms continues in full force.
Dispute Resolution – United States Only
This section applies only if you are located in the United States. It does not apply to users located in Canada, who are subject to the governing law and forum provisions above.
Informal resolution. Before commencing any arbitration, you agree to contact us at privacy@pillexa.com and give us sixty (60) days to resolve your concern informally.
Agreement to arbitrate. If we cannot resolve your concern informally, you and Pillexa agree that any dispute, claim, or controversy arising out of or relating to these Terms, the Platform, or any product or service obtained through the Platform will be resolved by binding individual arbitration administered by the American Arbitration Association under its Consumer Arbitration Rules then in effect, rather than in court. The arbitration will be conducted by videoconference or in the county of your residence. The arbitrator's award may be entered in any court of competent jurisdiction.
Class action waiver. You and Pillexa agree that each may bring claims against the other only in an individual capacity, and not as a plaintiff or class member in any purported class, collective, consolidated, or representative proceeding. The arbitrator may not consolidate the claims of more than one person and may not preside over any form of class or representative proceeding. If this class action waiver is found unenforceable as to any claim, then this entire Dispute Resolution section does not apply to that claim, and that claim will proceed in court in accordance with the governing law and forum provisions above.
Your right to opt out. You may opt out of this Dispute Resolution section by sending written notice to privacy@pillexa.com or the mailing address below within thirty (30) days of first accepting these Terms, stating your name, the email address associated with your account, and that you wish to opt out of arbitration. Opting out will not affect any other part of these Terms.
Exceptions. Either party may bring an individual claim in small claims court if it qualifies. Either party may seek injunctive or equitable relief in court to protect its intellectual property rights. Nothing in this section prevents you from reporting a concern to, or limits the authority of, any government authority, regulator, licensing body, or attorney general.
Coordinated claims. If twenty-five (25) or more claimants submit demands for arbitration raising substantially similar claims and are represented by the same or coordinated counsel, the demands will be resolved in staged batches of no more than fifty (50) at a time.
Severability and survival. Except as stated in the class action waiver above, if any part of this section is found unenforceable, the remainder continues in effect. This section survives termination of these Terms.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact our Privacy Officer at:
Attn: Privacy Officer
privacy@pillexa.com
or via mail at:
105-15336 67 Ave, Surrey, BC V3S 7C6
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.
You have the right to make a complaint at any time to the relevant privacy regulator. We would, however, appreciate the opportunity to address your concerns before you do so. You can contact the Information & Privacy Commissioner for BC or the relevant provincial privacy commissioner for your province or state of residence.