PHARMACY PRIVACY POLICY
This privacy policy aims to give you
information on how PharmAppy collects and processes your personal data. It also explains your rights
in relation to your personal data and how to contact us or supervisory
authorities in the event you have a complaint.
We collect, use and are responsible for certain
personal data about you.
The PharmAppy App enables authorised Pharmacists to process repeat prescriptions, and requests for pharmacy services that have been ordered by their patients who are registered with the PharmAppy App. A secure messaging service is also provided so that Pharmacists can easily communicate with their patients.
Important information and who we are
PharmAppy Services Limited is the controller and is responsible for your personal data (collectively referred to as “PharmAppy”, "we", "us" or "our" in this policy).
We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.
Contact details
Our full details are:
· Full name of legal entity: PharmAppy Services Limited
· Email address: hello@pharmappy.co.uk
· Postal address: 317 Golden Hill Lane, Leyland, Lancashire, England, PR25 2YJ
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
The ICO can be contacted:
· by phone +44 303 123 1113
· by writing to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
· via their website at https://www.ico.org.uk/concerns
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
This version was last updated on 02.12.23. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the app / pharmacy portal. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of our app / pharmacy portal or our services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links
Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
Personal data, or personal information, means any information about an individual from which that person can be identified, It does not include data where the identity has been removed (anonymous data).
The personal data you provide to us, as well as that we collect about you, is necessary for us to administer your PharmAppy account and action your requests. Without it we may not be able to do so.
· Identity Data includes first name, last name, username or similar identifier, email, password, title and gender, phone number, Pharmacy name and address, the pharmacy services you offer and your active opening / working hours.
· Contact Data includes billing address, delivery address, email address and telephone numbers.
· Financial Data includes bank account and payment card details.
· Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the App and/or website.
· Profile Data includes your login email address, purchases or orders made by you, your interests, preferences, feedback and survey responses.
· Usage Data includes information about how you use our website, products and services.
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
· Where you have consented before the processing.
· Where we need to perform a contract we are about to enter or have entered with you.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal or regulatory obligation.
· Where we need to perform the contract we are about to enter into or have entered into with you.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
|
Purpose/activity |
Type of data |
Lawful basis for
processing |
|
To register you as a new customer and create your PharmAppy account |
Identity Contact |
Performance of a contract with you |
|
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
Identity Contact Financial Transaction Marketing and Communications |
Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) |
|
To administer your PharmAppy account including: (a) To enable you to access prescriptions and records of patient details entered by the PharmAppy App users (b) To facilitate the receipt and processing of repeat prescriptions and pharmacy services for PharmAppy App users, who are registered for service by the PharmAppy App user (c) To enable you to communicate with patients via secure App messages (d) To provide you with support so that technical problems can be fixed |
Identity Contact Technical Profile |
Performance of a contract Necessary for our legitimate interests (e.g. to provide the PharmAppy App service, to provide customer support and to troubleshoot problems etc). |
|
To manage our relationship with you which will include: (a) notifying you of changes to the App or any Services (b) Notifying you about changes to our terms or privacy policy (c) Asking you to leave a review or take a survey |
Identity Contact Profile Marketing and Communications |
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep pour records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey |
Identity Contact Profile Usage Marketing and Communications |
Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
|
To administer and protect our business and this App including troubleshooting, data analysis and system testing |
Identity Contact Technical |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) Necessary to comply with a legal obligation |
|
To deliver content and advertisements to you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App |
Identity Contact Profile Usage Marketing and Communications Technical |
Consent Necessary for our legitimate interests (to develop our products/Services and grow our business) |
|
To carry out personal data and/or marketing analysis,
profiling or create statistical or testing information to help us personalise
the services we offer you and to understand our users/customers better,
understand what our users/customers want and how they use our products and
services |
Technical Usage |
Necessary for our legitimate interests (e.g. in order to help with improving our service and research into the quality of treatment. |
|
To make suggestions and recommendations to you about goods or services that may of interest to you |
Identity Contact Technical Usage Profile Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transaction.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data
without your knowledge or consent, in compliance with the above rules, where
this is required or permitted by law.
Disclosures of your personal data
We may disclose your personal information to
third parties:
· If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
· To a contractor appointed by us to deliver elements of the App or the Services on our behalf;
· For administration of your PharmAppy App account;
· Other trusted third parties, who will receive it as data
controllers in their own right (such as auditors, consultants and legal
advisers). In such cases, we will ensure that the appropriate contracts and
safeguards are in place;
· Third party processors for website and App analytics purposes;
· In order to comply with our legal, regulatory and statutory
obligations, sometimes we also need to pass your personal information to third parties,
such as courts, law enforcement agencies, our insurers, our auditors, and our
professional advisers;
· In connection with a potential sale or transfer of part or all of our business. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access and use the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
We will retain a record of your personal data in accordance with relevant law and the following criteria:
· Where we have a reasonable business need to do so, for example, in order to manage our relationship with you;
· Where we are providing products and/or services to you and then for as long as someone could bring a claim against us in respect of those products or services; and/or
· In line with any legal and regulatory requirements or guidance in respect of retention periods.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your
legal rights
You have a number of important legal rights regarding the manner in which
the personal data relating to you is used.
We have outlined below the key rights which we believe may be relevant to
your use of the App and/or the Services.
If you would like to exercise any of these rights then please contact us
using the information in the section headed ‘Important information and who we
are” above. Please note that you may be
asked to provide us with reasonable proof of your identity so that we can be
sure that we are discussing or providing your personal data with, or to, you
(or if someone is making a request on your behalf, we need to check that they
have the authority to do so).
Please note that the pharmacy services provided to you by your Pharmacy
are delivered subject to their own terms and conditions and their own privacy
policy and it is therefore important that you check the relevant terms and
policies before you use those services to ensure that you are happy with the
same.
· Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
· Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
· Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. For example, if you choose to withdraw consent in respect of Medicines Data then the Services will no longer function. We will advise you if this is the case at the time you withdraw your consent.