Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information.
Medical information includes information pertaining to an individual’s health and disease state that is provided by the user or their health professional. For example, this may include any condition, type of medication prescribed, regularity of medication, medication schedule, implied adherence data and health insurance details.
What personal information do we collect?
We may collect the following types of personal information relating to you:
- mailing or street address;
- email address;
- telephone number and other contact details;
- age or date of birth;
- health insurance and/or pharmacy details or such other identifier or signup code as is provided by the relevant Commercial Partner that authorises your access to our services (where your access to our services is provided through your membership or affiliation with an entity that is a “Commercial Partner” of ours);
- your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, recordings of the user interface when using the Perx app, advertising data, IP address and standard web log information;
- details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
- any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
- information you provide to us through customer surveys; or
- any other personal information that may be required in order to facilitate your dealings with us.
What medical information do we collect?
We may collect the following types of medical information relating to you:
- Medical conditions;
- Medication brand names, drug names, dosage and other relevant information;
- Medical and health improvements, results and outcomes;
- Timing and regularity of medication schedule;
- Consumption of medication, both verified by the app and self-reported;
- Photos of your medication as uploaded into the app;
- Prescription scripts both issued and dispensed;
- Implied adherence rate, both verified by the app and self-reported;
- General Practitioner’s name and practice details,
- Health insurance provider;
- Health insurance membership number;
- Health insurance policy type;
- Pharmacy locations visited;
- any other medical information that may be required in order to facilitate your dealings with us.
How we collect your information
We may collect these types of information either directly from you, or from third parties. We may collect this information when you:
- register on our website or app;
- communicate with us through correspondence, telephone, chats, email, or when you share information with us from other social applications, services or websites;
- interact with our sites, services, content and advertising.
We may also collect information:
- with your consent through your medical practitioner and Commercial Partners;
- with your consent, through your pharmacy dispensing records, including the details of the medication dispensed, dates dispensed, cost of medication and repeats left;
- with your consent, through medical information systems such as government health records, systems used by medical professionals, pharmacy management systems and other similar systems;
- while conducting customer satisfaction and market research surveys; or
- with your consent, in the course of supporting you either directly or through your pharmacy or health professional.
Why do we collect, use and disclose personal information and medical information?
We may collect, hold, use and disclose your personal information for the following purposes:
- to enable you to access and use our website, services and app;
- to operate, protect, improve and optimise our website, services and app, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our Commercial Partners. We may send you marketing and promotional messages on behalf of our Rewards Partners however you will only receive marketing and promotional messages and information directly from Rewards Partners where you have accepted a reward from a Reward Partner;
- to administer and establish your eligibility for rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
- to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and/or
- to consider your employment application.
Do we use your personal information for direct marketing?
We and our Commercial Partners may send you direct marketing communications and information about our service and products and related services/products. In addition, our Rewards Partners who provide rewards (i.e. gifts or discounted goods or services) may send you direct marketing communications and information but only where you accept a reward from them. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link). You must opt out of communications from Commercial Partners or Rewards Partners to them directly.
We may receive remuneration from third parties for communicating with you about their products or services, or for providing you with promotional items from them.
To whom do we disclose your personal information?
- our employees;
- Reward Partners but only where you have accepted a reward from that particular Reward Partner, in which case we may share only that personal information which is necessary for the particular Reward Partner to issue the reward to you. We will never disclose your medical information to a Reward Partner and will never provide your personal information to Reward Partners, other than in connection with a reward that has been accepted by you;
- third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
- professional advisers, dealers and agents;
- Commercial Partners where they have authorised your access to the services;
- payment systems operators (e.g. merchants receiving card payments);
- our existing or potential agents, business partners or partners;
- anyone to whom our assets or businesses (or any part of them) are transferred;
- specific third parties authorised by you to receive information held by us; and/or
- other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
To whom do we disclose your medical information?
- our employees;
- the Commercial Partner who authorises your access to the services; and/or
- medical practitioners and/or pharmacists nominated by you as authorised to access your medical information.
We may use your personal and medical information in de-identified form (de-identification being a process by which a collection of data or information is altered to remove or obscure personal identifiers and personal information) to assist us in running our business. We may also provide de-identified information in aggregated form, to third parties. This information may include (but is not limited to):
- locations of users;
- use of particular medicines;
- implied medication adherence rates and patterns (both verified and self-reported);
- medical and health improvements, results and outcomes;
- dispense records of scripts filled/not filled, and script filling behaviour and patterns that users have been prescribed by their medical professional; and
- functions accessed by users including analytics of use of our products and services.
When your personal information and medical is included in de-identified, aggregated data, it is not possible to identify you or anything about you from that data.
Disclosure of information outside Australia
We may disclose personal information and medical information outside of Australia but only to third party service providers which are engaged by us to act on our behalf and assist with our business functions and delivery of the services to you that may be located in various countries.
When you provide your personal information and medical information to us, you consent to the disclosure of your information outside of Australia to our service providers and further consent that clause 8.1 of the APPs shall not apply to such disclosure and you consent to such disclosure without the application of clause 8.1 of the APPs. You acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the APPs.
Using our website and cookies
We may collect personal information about you when you use and access our website and applications.
While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.
We may hold your personal information and medical information in either electronic or hard copy form. We take reasonable steps to protect your personal information and medical information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, we host our servers in Australia and all web-hosting is SSL-encrypted. However, we cannot guarantee the security of your personal and medical information.
Accessing or correcting your personal information
You can access the personal and medical information we hold about you by contacting us at firstname.lastname@example.org. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal and medical information.
If you think that any personal and/or medical information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.
Making a complaint
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal and/or medical information, you can contact us at email@example.com. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
Perx Support Team
Effective: 8 December 2017