Privacy Policy - Pharmlink

Privacy Policy

1. Introduction

PHARMLINK PTY LTD (ACN 685 419 318) (we, us, our) recognises the importance of protecting the privacy and the rights of individuals in relation to their personal information.
This Privacy Policy sets out our commitment to protecting the privacy of your personal information and how it is collected whether through our website (Website) directly from you or otherwise.
We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles, and we manage the collection and disclosure of your personal information in accordance with these requirements.
If you do not wish to provide personal information to us, then you do not have to do so. However, this may affect your use of our Website and services offered on it.

2. Definitions

Carer means a carer or support worker of the Client.
Connected Pharmacy means the Pharmacy, or Pharmacies which are connected for the purposes of the provision of our services.
Client means a Home Care Package participant who is being provided with goods and services.
Client Information means the Client’s: name; address; phone number; email address; Carer’s name and phone number; Home Care Provider and location; Home Care Type (Aged Care or NDIS); Home Care Package number (My Aged Care ID 8 digits; or NDIS Number 9 digits also referred to as the NDIS Participant Number); preferences for point of contact, delivery options and Connected Pharmacy; and monthly allowance for meals and consumables.
Home Care Package means a Client’s government issued support package, either: My Aged Care (for older Australians); or the NDIS (for people with disability).
Aged Care Act means the Aged Care Act 1997 (Cth) and its related regulations.
My Aged Care means the government’s aged care system which provides information, manages eligibility assessments, and connects people to services pursuant to the Aged Care Act.
NDIS means the National Disability and Insurance Scheme.
NDIS Act means the National Disability Insurance Scheme Act 2013 (Cth) and its related regulations.
Partner means Directo Pty Ltd (ACN 626 005 310).
Pharmacy means a pharmacy registered to use our services and provide/supply goods and services to the Client, including its contractors, agents or employees, or any other individuals that assist in the facilitation of its orders.
Pharmacy Information means the information the Pharmacy is required to provide us including: Pharmacy name; Pharmacy street address; Pharmacy ABN/ACN; Pharmacy primary contact name; Pharmacy primary contact role; Pharmacy primary contact number; Pharmacy primary contact email address; Pharmacy accounts payable contact; Pharmacy accounts payable email address; Pharmacy accounts payable phone number; services to be offered by the Pharmacy (e.g. frozen meals or delivery); supply warehouses Pharmacies have access to; and bank account details.
PharmLink Portal means the portal accessible here: www.pharmlink.com.au.
Provider means a Home Care Provider, whether registered or unregistered, who is using our services and provides its services to the Client in accordance with the Aged Care or NDIS Act, including via its contractors, agents, or employees.
Provider Information means: business name; business ABN/ACN; business type (Aged Care, NDIS, both); Provider business number (NDIS, or Home Care Provider Government issued number); Carer name; Carer phone number; Carer email address; Carer role; Carer branch/region; Carer branch/region street address; accounts payable contact; accounts payable email address; accounts payable phone number; and email address to send invoices and statements to.

3. What is personal and sensitive information?

When used in this Privacy Policy, the term “personal” or “sensitive” information has the meaning given to it under the Privacy Act.
In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation.
If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
With respect to “sensitive information”, it is personal information which includes (but is not limited to) information about an individual’s race or ethnic origin, political opinion or memberships, religious beliefs and health information.
We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users operate on our Website.
To the extent we collect information which is not considered personal information, you acknowledge that the Privacy Act will not apply to the collection, use, disclosure and general dealings associated with that information.
Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

4. What information we may collect from you

We may collect the following information (personal, sensitive and non-personal) from you:

names;
email addresses;
telephone numbers;
business management information;
billing, mailing, business and/or residential address;
business or company numbers and names;
banking, credit card, or other online payment details to process purchases;
Client Information;
Pharmacy Information;
Provider Information; and
any other contact or personal information which we collect during conversations with Providers and Pharmacies.

We collect personal information about you so that we can perform our business activities and functions and provide the best possible quality of customer service to you.

We collect, hold, use and disclose your personal information for the following purposes:

to provide our services;
to conduct internal record keeping;
to identify and understand user needs;
to enable us to process your personal data;
to facilitate the supply of goods ordered;
to assist in invoicing payments;
to personalise and customise your experiences on our Website;
to send communications requested by you;
to answer enquiries;
to provide to third parties to assist us in the provision of our services generally;
to conduct market research, business development and marketing activities (including direct marketing);
to send you promotional information about our services and about third parties that we think you may find interesting;
to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in cooperation with any governmental authority; and
to contact you.

5. How do we collect your personal information?

We collect your personal information directly from you, or your Provider on the Client’s behalf, unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in various ways including:

when you make an enquiry about our services;
when you fill in any of our online forms;
through your access and use of our Website, including when you register to use the Pharmlink Portal;
during conversations between you and our representatives or through any other means or platforms, including social media;
when you ask to be placed on one of our subscription/mailing lists;
when you engage our services;
when you use or access our social media pages, which may be collected through use of web analytics tools, “cookies” or other similar tracking technologies that allow us to track and analyse your service usage;
when you visit any links shared via our social media posts, emails or other landing pages.

6. What happens if we can’t collect your personal information?

If you do not provide us with the personal information described above, some or all of the following may happen:

we may not be able to provide our services to you, either to the same standard or at all;
we may not be able to provide you with information about services that you may want, including information about special promotions; or
we may be unable to tailor the content of our Website to your preferences and your experience of the Website may not be as enjoyable or useful.

7. Our Website

Website User Tracking Experience

We may use tracking software to review and improve your experience of our Website, Surveys and landing pages. In particular, we may use Facebook Pixel, Infusionsoft, Active Campaign, Google Analytics, YouTube or any other platform we deem fit.

When visiting our Website, the Website server makes a record of the visit and logs the following information for statistical and administrative purposes:

the user’s server address – to consider the users who use the Website regularly and tailor the Website to their interests and requirements;
the date and time of the visit to the Website – this is important for identifying the Website’s busy times and ensuring maintenance on the Website is conducted outside these periods;
pages accessed and documents downloaded – this indicates to us which pages or documents are most important to users and also helps identify important information that may be difficult to find;
duration of the visit – this indicates to us how interesting and informative our Website is to users;
the type of browser used – this is important for browser specific coding; and
in order to optimise our Website and better understand it’s usage, we collect the visiting domain name or IP address, computer operating system, browser type and screen resolution.

We may use advertising products, such as Remarketing with Facebook, Google Analytics and Google Analytics Demographics and Interest Reporting. Google Analytics collects data about our Website traffic via Google Advertising cookies and anonymous identifiers.

Data collected via these Google products is not linked with any personally identifiable information you submit while on our Website. If you wish to opt out of the Google Analytics data collection, you may do so on Google’s Site at tools.google.com/dlpage/gaoptout.

Cookies

When you access our Website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer. This enables us to recognise your computer and greet you each time you visit our Website without bothering you with a request to register.
We also use cookies to measure traffic patterns, to determine which areas of our Website have been visited and to measure transaction patterns in the aggregate.
We use this to research our users’ habits so that we can improve our services. Our cookies do not collect personal information. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them. We may log IP addresses (that is, the electronic addresses of computers connected to the Internet) to analyse trends, administer the Website, track users’ movements, and gather broad demographic information.
The Website may contain content and sharing tools embedded from various social networks, such as Facebook. These suppliers may use and place cookies on your device. We do not have access to, and cannot control, these cookies or the personal data and information that they may collect. You therefore need to check the websites of these suppliers to get further information on how they manage cookies and what information their cookies collect.

Security

As our Website is linked to the Internet, and the Internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online.
We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the Internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Links

We provide links to websites outside of our Website, as well as to third party websites. These linked sites are not under our control, and we cannot accept responsibility for the conduct of any companies, businesses, affiliates, advertisers and sponsors, linked to our Website.
Before disclosing your personal information on any other website or to any third party, we advise you to examine the terms and conditions of using that website and its privacy policy. Third party websites are responsible for informing you about their own privacy practices.

8. Who do we disclose your information to?

We may disclose your personal information to:

our directors, employees, agents, contractors or service providers, including, without limitation, consultants web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors, for the purposes of operating our Website or our business, fulfilling requests by you, and to otherwise provide services to you;
suppliers and other third parties as part of the provision of our services, which may include overseas parties;
Connected Pharmacies;
credit reporting agencies and courts, tribunals, regulatory authorities where customers fail to pay for goods or services provided by us to them, and other law enforcement officers as required by law; and
any other organisation for any authorised purpose with your express consent.

We only disclose this information if the third party has agreed to comply with the standards in our Privacy Policy.

If there is any change or potential change to the control of our business pursuant to the sale, assignment or transfer of the business, or business assets, its assets and/or liabilities, we reserve the right to sell, assign and/or transfer our user databases, together with any personal information and non-personal information contained in those databases to the extent permitted by law. In that event, your personal information may be disclosed to a potential purchaser, assignee or transferee, however any disclosures will only be made in good faith and where confidentiality is maintained.

9. Direct marketing materials

We may send you direct marketing communications and information about our services that we consider to be of interest to you. These communications may be sent in various forms, including mail, SMS and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth).
If you indicate a preference for a method of communication, we will endeavor to use that method whenever practical to do so.
In addition, at any time you may opt out of receiving marketing communications from us by contacting us at info @pharmlink.com.au or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our subscription/mailing list.
We do not provide your personal information to other organisations for the purposes of direct marketing.

10. Security and data quality

We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure.
We strive to ensure the security, integrity and privacy of personal information that you submit to us through our Website. Unfortunately, no data transmission over the internet can be guaranteed to be totally secure.
We endeavour to take all reasonable steps to protect the personal information you may transmit to us, or, which we obtain from our services. Once we do receive your transmission, we will also use our best efforts to ensure its security on our systems.
In addition, our employees and the contractors who provide the services related to our information systems are obliged to respect the confidentiality of any personal information held by us.
We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed or when we are no longer required by law to retain it (whichever is the latter).
Should a data breach involving personal information occur: We will take positive steps to address the breach in a timely manner and take remedial action such that the data breach does not result in serious harm. We will undertake reasonable and expeditious assessment to determine if it is an ‘eligible data breach’, that is a breach likely to result in serious harm to any individual affected.
In compliance with Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth), we agree that if we become aware of reasonable grounds to believe an eligible data breach has occurred, we will promptly notify the Office of the Australian Information Commissioner (Commissioner), the Association of Market and Social Research Organisations (AMSRO) and the affected individuals at likely risk of serious harm.

11. How long do we retain your personal data?

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law, we must keep basic information about our customers (including contact, identity, financial and transaction data) for five years for Australian tax law purposes.
Without limitation to clause 11.3, we retain your information for seven years.
In some circumstances, you can ask us to delete your data; see your legal rights below for further information.
In some circumstances we may 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.

12. How can you access and correct your personal information?

You may request access to any personal information we hold about you at any time by contacting us at the following addresses:

PharmLink Pty Ltd

166 Rocket St, Bathurst, NSW 2795

Email: info @pharmlink.com.au

Your information will be made available within 14 days of receiving your request, without any charges to you.

There may be instances where we cannot grant you access to the personal information we hold. For example, you may be refused access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we or our Partner will give you written reasons for any refusal.

If you believe that personal information held about you is incorrect, incomplete or inaccurate, then you may request an amendment. We will consider if the information requires correction. If we do not agree that there are grounds for correction, then we will add a note to the personal information stating that you disagree with it.

13. How can you withdraw your consent to this Privacy Policy?

You may withdraw your consent to this Privacy Policy at any point. If you wish to withdraw your consent to our collection and retention of your data, please contact our Data Protection Officer at info @pharmlink.com.au and we can arrange for your data to be deleted, destroyed or returned to the extent we are permitted by law. However, this may affect your use of this Website and services offered on it.

You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us at the email address listed in this Privacy Policy.

To unsubscribe from our e-mail database, or opt out of any communications, please contact us at the email address listed at the start of the Privacy Policy, with “Unsubscribe” in the subject line of the e-mail.

14. What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it.

We will treat your complaint confidentially, investigate your complaint and aim to ensure that we contact you and your complaint is resolved within a reasonable time (and in any event within the time required by the Privacy Act).

15. Contacting us

If you have any questions about this Privacy Policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please contact us at:

PharmLink Pty Ltd

166 Rocket St, Bathurst, NSW 2795

Email: info @pharmlink.com.au

You may also contact us directly at the email address listed in this Privacy Policy but understand that our Partner deals with the operational matters concerning the Website.

16. Changes to our Privacy Policy

All personal information held will be governed by our most recent Privacy Policy, posted on our Website, where the Privacy Policy will be located.

Any changes to this Privacy Policy may be advised to you by updating this page on our Website. We encourage you to check this page from time to time for any changes.