Privacy

Privacy Policy

This privacy policy sets out how InstantScripts Pty Ltd (ACN 629 120 234) (“we”) treat the privacy of customers and others with whom we interact, including patients, suppliers, pharmacy staff, cosmetic nurses and managers of cosmetic clinics.

In this privacy policy, the term “personal information” has the meaning in the Privacy Act 1988 (Cth) and under that legislation includes information about an identifiable individual, including names, addresses, telephone numbers, email addresses, dates of birth, credit and banking details, details of professional memberships and if and where applicable, includes information that constitutes “sensitive information” such as health information.

1. Background

We operate a business providing (among other things) a secure platform generating pharmaceutical prescriptions for users following their completion of a short digital medical consultation. These services are provided to the customer either via a mobile application or at a terminal located within a pharmacy, cosmetic clinic or other health facility.

2. Collection and Storage of Personal Information and Data

We collect personal information about individuals. Our usual approach is to collect personal information directly from the individual concerned.

The types of personal information we collect or may collect includes names, dates of birth, email addresses, signatures, mailing addresses, residential addresses, Medicare numbers, health fund details; credit card details, payment and transactional information and some health information such as details of medications already prescribed and/or taken or to be taken by the individual, as well as medical history, together with any information we are required to collect by law. These may be collected in relation to customers wishing to obtain scripts, pharmacy staff, clinical staff including management and nursing staff and medical professionals including prescribing doctors.

For example, we collect personal information in circumstances including:

(i) from you, when you use the InstantScripts system to request a script;
(ii) to confirm your identity when you deal with us;
(iii) for the purposes of providing information to or receiving information from a medical professional to facilitate the issuing of a script;
(iv) when paying for goods with credit cards;
(iii) when customers receive cosmetic injectable treatments at one of the cosmetic clinics our terminals are located in;
(v) when you telephone us, visit our website or meet with us and make an enquiry to which a later response is requested and to do so requires your contact details;
(iii) when recording medical queries, complaints and adverse events;
(iv) when you ask to be included on marketing distribution lists, agree to receive targeted advertising material and communications, or when you interact with us through social media platforms;
(v) for other regulatory purposes; and
(vi) when evaluating job applicants and personnel, including their contact details, employment history and educational qualifications. This may include “sensitive information” as defined in the Privacy Act. Further details about our privacy policy and practices for job applicants will be available at the time of application.

3. Cookies

We may use ‘cookies’ to collect data (typically not personal information) relating to your general internet usage. This data may include IP-addresses, browser versions, number of visits and similar such data relating to your navigation of the internet and our site. A cookie is a small text file that is placed on your computer’s hard drive. Cookies help us to improve our site and to deliver a better and more tailored service, for instance by storing information about your preferences and allowing us to recognise you when you return to our site.

You may refuse to accept cookies by activating settings on your internet browser. However, please note that if you select such settings you may be unable to access certain parts of our site.

4.Storage/ security of personal information

We hold personal information in our own encrypted, locally stored and secure databases. We take all reasonable steps to protect your personal information, including internal and external security, restricting access to personal information to those who have a need to know, maintain technological products to prevent unauthorised computer access and regularly reviewing our technology to maintain security.

However, unfortunately, the internet is not always a secure place and we cannot guarantee total security of your personal information in all circumstances.

When you provide personal information to us, you warrant that it is accurate, current and complete and undertake to maintain the accuracy, currency and completeness of the personal information we retain.

We treat website and credit card security seriously and endeavour to provide a secure, safe platform through which to conduct transactions.

We will take reasonable steps to destroy or de-identify personal information if it is no longer needed for any purpose for which it may be used or disclosed in accordance with the Privacy Act.

5.Use of Personal Information

We may use personal information for the purpose of marketing but only where such use complies with the Privacy Law and the Australian Privacy Principles in particular.

We use the personal information collected from you for the purpose it was provided or collected (as indicated above), including in the following ways:

(a) To assess your requests for scripts;
(b) To respond to enquiries received from you;
(c) To process, confirm, fulfil and update you about your orders;
(d) To perform authorised financial transactions with you;
(e) To verify your identity and to assist you if you have forgotten any user name or password;
(f) To communicate with you and provide you with information (whether by email, post or other means) about our products or services, where you have requested or consented to receiving this from us or where this provision is otherwise permitted under the Australian Privacy Principles;
(g) To facilitate communication by third parties (whether by email, post or other means) in relation to products or services that may be of interest to you, where you have requested or consented to us providing your personal information to third parties for that purpose;
(h) To enable research and market analysis, where you have consented to same;
(i) To notify you about changes to our goods and services;
(j) To address medical queries, complaints and adverse events and provide adverse reaction reports for the purpose of reporting to regulatory bodies such as the Therapeutic Goods Administration;
(k) To receive and address feedback or complaints from you; and
(l) To protect our legal interests and fulfil our regulatory obligations (if and to the extent necessary).

All customers and others with whom we interact have the option to opt-out of receiving marketing communications from us. If you do not wish to continue to receive electronic marketing communications from us and/or selected third parties you should opt-out by clicking on the “unsubscribe” link in any email communications that we might send you. If you request us not to send other electronic communications, we will also comply with that request to the extent reasonably practical.

6. Disclosure of Personal Information

We may disclose your personal information to any of our related group companies. They will only use it for the same purposes that we may under this policy. We may provide personal information to third parties outside our group companies for limited purposes, such as to help us in providing or offering goods and services to customers, where you have provided your consent.

Those persons and businesses may include:

(a) Medical professionals for the purpose of issuing scripts;
(b) Organisations who carry out credit, fraud and other security checks;
(c) Couriers and delivery businesses (where we arrange to deliver goods to you or persons you have requested us to send deliveries to);
(d) Third party suppliers of goods or services that may be of interest to you (with your consent);
(e) Third parties that carry out market research;
(f) Third party software providers who store details of customer account for us or who provide other IT services; and
(g) Marketing businesses engaged by us to disseminate materials to which recipients have consented (if applicable).

We may also disclose your personal information to third parties outside our group of companies:

(a) Where we have your express permission to do so;
(b) Where it can reasonably be inferred from the circumstances that you consent to the disclosure to the third parties;
(c) If we or substantially all of our assets are acquired by a third party, in which case personal information which we hold about our customers may be one of the transferred assets (subject to the same constraints on use and disclosure as under this policy); and
(d) If we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation, or in order to enforce or apply our terms and conditions; or to protect our rights, property, or safety of that of our personnel or customers . This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Except as above, we limit the information we provide to third parties to the information they need to help us and pharmacies provide or facilitate the provision of goods and services to you. We deal with third parties that are required to meet the privacy standards required by law in handling your personal information, and use your personal information only for the purposes that we gave it to them.

We do not disclose personal information to business located outside Australia.

7. Questions and concerns and access to/ correction or updating of your personal information

You have a right to access the personal information we hold about you and to raise concerns or complaints or ask for corrections. To raise privacy concerns, including to obtain a copy of the personal information we hold about you, please write to us at:

InstantScripts Pty Ltd

Level 19, 644 Chapel Street, South Yarra VIC 3141

[email protected]

Please provide sufficient detail about the personal information in question to help us locate it. We will then use commercially reasonable efforts to promptly determine if there is a problem and take the necessary corrective action within a reasonable time.

8. Changes to our privacy policy

We may modify, alter or otherwise update this privacy policy at any time. We will post revisions on our website. We encourage you to review this policy from time to time.

Last update: March 2019