PharmacyConnect Privacy and Cookie Policy
Effective Date: 8th March 2024
Introduction
This policy applies together with the terms of use to your access and use of the app published by a
Pharmacy which is provided on the PharmacyConnect platform (the ‘Pharmacy App’). The Terms and
Conditions of the Pharmacy App identify the Pharmacy and their contact details. This policy sets out
the basis on which any personal information that the Pharmacy collects from you, or that you
provide to the Pharmacy, will be processed by the Pharmacy. ‘Personal information’ means
information about a living individual who can be identified from that information (either by itself or
when it is combined with other information).
This policy is issued on behalf of the Pharmacy publisher of the Pharmacy App . This Pharmacy, and
contact details for it, is identified within the Pharmacy App itself and also Google’s Play Store and
Apple’s App Store, as appropriate. The Pharmacy is the data controller for the personal information
that is collected through the services subject to this policy. In this Privacy Policy, “we” means the
Pharmacy which publishes the Pharmacy App.
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We are committed to protecting your personal data and respecting your privacy. Please read the
following carefully to understand our practices regarding your personal data and how we will treat
it.
We are committed to protecting your data and respecting your privacy. If you have any queries
about this Privacy Policy or in relation to how we use your personal data, please contact us using the
contact details contained in the Pharmacy App. If you wish to raise a complaint on how we have
handled your personal information, you can contact us and our team will investigate the matter. We
hope that we can address any concerns you may have, but you have the right to make a complaint at
any time to Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland.
Changes to the privacy policy
We keep our Privacy Policy under regular review and may change it from time to time by posting a
revised version and updating the ‘Effective Date’ above. The revised version will be effective on the
‘Effective Date’ listed. We will provide you with reasonable prior notice of substantial changes in
how we use your information, including by email. We may provide notice of changes in other
circumstances as well. If you are unhappy with these changes, you can cancel your account at any
time and/or stop your use of our services.
What type of personal data do we collect?
We may collect, use, store and transfer different kinds of personal data about you or your listed
dependants on the Pharmacy App as follows:
Identity Data: may include first name, last name, username or similar identifier, title, date of birth,
photograph or profile image. In certain circumstances we may also collect and store an ID Document
and utility bill.
Contact Data: may include residential address, email address and mobile telephone number. If at
any point in the future you change your details, you must tell us promptly about those changes.
Financial Data: may include bank account and/or payment card details.
Transaction Data: includes details about payments to and from you and details of in-app purchases
or services used.
Device Data: includes the type of mobile device you use, a unique device identifier such as the
mobile phone number used by the Device, mobile network information, your mobile operating
system, the type of mobile browser you use, and IP Address.
Content Data: includes information stored on your Device, including login information or other
digital content.
Profile Data: includes your username and password, in-app purchase and transaction history,
product shortlist and frequency, in-app communications, preferences, feedback and survey
responses, bonus history, details of your use of any of our services or your visits to any of our
website(s) and any other information we learn about you through our relationship with you and the
way you operate our services.
Marketing and Communications Data: includes your preferences in receiving marketing from us and
our third parties and your communication preferences.
Location Data: includes your geo-location data that determines your current location.
We may 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 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 Pharmacy App 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.
Other than a picture of you (which is considered biometric data and within the meaning of Special
Categories of Personal Data), which we may get access to if you register with us via a social network,
or if we need to ask you for a selfie photograph together with an ID Document in order to be able to
provide you with certain services, we do not collect any other 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).
In certain circumstances, when you apply for a service (and throughout your relationship with us) we
may need to collect a ‘selfie’ video or photograph and an ID Document from you. We would do this
in order to verify who you are as part of our legal obligations to carry out certain Anti-Money
Laundering and Counter-Terrorism Financing checks and for our own fraud detection purposes. You
do not need to provide us with this information, but if you don’t, we may not be able to offer some
or all our services.
How is your personal data collected?
We will collect and process the following data about you:
Information you give us. This is information you agree to give us about you by filling in forms in the
Pharmacy App or on any sites through which we offer our services or by corresponding with us (for
example, by email or chat), by phone or in person. It includes information you provide when you
register to use the App Site, download or register our App, subscribe to any of our services, search
for or use our services, enter a competition, promotion or survey, and when you report a problem
with the Pharmacy App or our services. If you contact us, we will keep a record of that
correspondence.
Information we collect about you and your device. Each time you use the Pharmacy App or use any
of our services we may automatically collect personal data including Device, Content and Usage and
Transaction Data. We collect this data using cookies and other similar technologies. Please see our
Cookie Policy (below) for further details.
Information we receive from third parties and publicly available sources. We may receive personal
data about you from third parties and public sources, such as:
Device data from analytics providers
Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
Identity, contact data and other account information from social networks such as Facebook, if you
choose to register to the Pharmacy App through that social network;
Fraud prevention and anti-money laundering /terror financing related information from government
agencies and/or private third party providers
Access to Contact List
When you download the Pharmacy App, you may be asked to grant permission to access your contacts. If granted, the Pharmacy App will access the names and phone numbers of your contacts. You can choose to deny the request if you’d like. You can allow access to your contacts later by selecting the Pharmacy App in your device Settings and enabling Contacts or via the prompts with the app.
How is the Contact List used?
If access is granted, the user’s contact list is used for app functionality and account management. Invites can be sent and/or received to link accounts. You can choose to Approve/Deny this request. You can undo linked accounts in your settings at any time.
Cookies
We use tracking technologies such as cookies to distinguish you from other users of the Pharmacy
App or services the Pharmacy App and to remember your preferences. For detailed information on
the cookies we use, the purposes for which we use them and how you can exercise your choices
regarding our use of your cookies, see our Cookie Policy further below.
How do we use your personal data?
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.
Marketing
We will only send you marketing communications, e.g., by email, push notifications or text, where
we have a lawful basis for doing so. We may use your Identity, Contact, Transactional, Usage and
Profile Data to form a view on what we think you may want or need, or what may be of interest to
you. This is how we decide which products, services and offers may be relevant to you (we call this
marketing).
You will receive marketing communications from us if you have requested information from us or if
you have registered with us and have not opted out of receiving marketing.
You can ask us to stop sending you marketing messages at any time following the opt-out links on a
marketing message sent to you or by contacting us at any time. You can stop receiving push
notifications by adjusting the Pharmacy App’s push notification settings on your phone.
We will not share your personal data with any third party for marketing purposes without first
getting your explicit express opt-in consent.
Which purposes will we use your personal data for
Purpose/activity : To install the Pharmacy App and register you as a new Pharmacy App user
Type of data: Identity, Contact, Device
Lawful basis for processing: Performance of a contract with you
2. Purpose/activity: To provide and administer the services throughout your relationship with us,
including linking your account to a payment card, executing your instructions; processing
transactions, resolving any queries or discrepancies and administering any changes.
Type of data: Identity, Contact, Financial, Transaction, Device
Lawful basis for processing: Performance of a contract with you, necessary for our legitimate
interests (e.g. to administer our service), to comply with a legal or regulatory obligation
3. Purpose/activity: To manage risk and crime prevention including (i) detecting, investigating,
reporting and preventing crime, (ii) obeying laws and regulations which apply to us, (iii) responding
to complaints and resolving them and (iv) to help us make decisions on your account.
Type of data: Identity, Contact, Financial, Transaction, Profile
Lawful basis for processing: Performance of a contract with you, to comply with our legal
obligations, necessary for our legitimate interests (e.g., to develop and improve how we deal with
financial crime)
4. Purpose/activity: To manage our relationship with you and ongoing customer services, including
notifying you of changes to the Pharmacy App or any services, and contacting you with information
relevant to the operation and maintenance of your account
Type of Data: Identity, Contact, Transaction, Device, Content, Financial, Profile, Usage, Marketing
and Communications
Lawful basis for processing: Performance of a contract with you, necessary for our legitimate
interests (e.g., to keep records updated, running and administration of our business), necessary to
comply with legal obligations (e.g., to inform you of any changes to our terms and conditions
5. Purpose/activity: To enable you to participate in a prize draw, bonus, competition or complete a
survey
Types of Data: Identity, Contact, Device, Profile, Marketing and Communications, Usage
Lawful basis for processing: Performance of a contract with you, necessary for our legitimate
interests (e.g. to analyse how customers use our products/services and to develop them and to grow
our business)
6. Purpose/activity: To administer and protect our business and the Pharmacy App including
troubleshooting, data analysis and system testing
Types of data: Identity, Contact, Device, Content, Profile, Usage, Location
Lawful basis for processing: Performance of a contract with you, necessary for our legitimate
interests (e.g., for running our business, provision of administration and IT services, network
security), to make recommendations to you about goods or services which may interest you, to
measure and analyse the effectiveness of the content that we serve you, to monitor trends so we
can improve the Pharmacy App
Lawful basis for processing: necessary for our legitimate interests (e.g., to develop our
products/services and grow our business), consent
We may monitor or record calls, emails, text messages or other communications in accordance with
applicable laws for the purposes outlined in the above section.
Disclosures of your personal data
We may share your personal data with our third party service providers, agents, subcontractors,
subprocessors and other associated organisations and group companies of the Pharmacy for the
purposes outlined in the ‘Purposes for which we will use your personal data’ section above. Entities
to which we pass your personal information may also include:
Companies and organisations that assist us in processing transactions you make via the Pharmacy
App and in providing services that you have requested, including any third parties providing services
to us, such as our Payment service Provider (PSP), correspondent banks, and market analysis service
providers;
Agencies providing identity verification services and other fraud and financial crime prevention
services to undertake required verification checks and help fight against financial crime including,
fraud Anti-Money Laundering and Terrorist Financing;
Other financial institutions and third parties where we are required either by law or by contract to
assist with the recovery of funds credited that have entered your account as a result of a misdirected
payment by such a third party;
Organisations which assist us with customer service facilities;
Anyone to whom we may lawfully transfer our rights and duties;
Any third party as a result of any proposed restructure, the assignment of any rights or obligations
under the Terms and Conditions, a sale or acquisition of the Company or of any associated entity,
provided that any recipient uses your information for the same purposes as it was originally supplied
to us and/or used by us;
Regulatory and law enforcement authorities whether they are outside or inside of the EEA, where
the law allows or requires us to do so;
Third parties where the disclosure is permitted by law, it is necessary for our legitimate interests or
those of a third party, and it is not inconsistent with the purposes listed above.
When using third party service providers, they are required to respect the security of your personal
data and to treat it in accordance with the law.
International Transfers
Some of our third party service providers are based outside the EEA so their processing of your
personal data will involve a transfer of data outside the EEA.
When we transfer your personal data out of the EEA, at least one of the following safeguards will be
implemented:
We will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data by the European Commission. For further details, see
European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European
Commission which give personal data the same protection it has in Europe. For further details, see
European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the
Privacy Shield which requires them to provide similar protection to personal data shared between
Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Data Security
We take measures, including administrative, technical and physical safeguards, to try to protect your
personal data from loss, theft, misuse and unauthorised access, disclosure, alteration and
destruction.
With respect to our Users’ payment card information – whenever you enter your card information
into the Pharmacy App , those details are encrypted and passed directly to our payment service
provider (‘PSP’). Upon receiving your information, our PSP sends us a token (consisting of random
letters and numbers) and small amounts of information about your payment card (the last four digits
of the card number, the card type and expiry date). The token (not your card details) is then used to
effect payments for the products or services you purchase through our app. We reserve the right to
change our payments gateway at our sole discretion, provided any such payment gateway meets
this security compliance level. You will be notified in advance if any changes to our payments
gateway require modification to this Privacy Policy.
Data retention
We will retain your personal data for as long as reasonably necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or
reporting requirements. We may retain your personal data for a longer period in the event of a
complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship
with you.
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, regulatory, tax, accounting or
other requirements.
We have to keep basic information about our customers (including Contact, Identity, Financial and
Transaction Data) for at least 5 years after they cease being customers for legal and regulatory
purposes. However we will usually keep personal data for at least 6 years after the end of your
contractual relationship with us in accordance with appropriate limitation periods.
In some circumstances you can ask us to delete your data: see ‘Your legal rights’ section 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
Under certain circumstances you have the following rights under data protection laws in relation to
your personal data. You can exercise any of these rights at any time by contacting us.
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 we no longer need to process your information for the purposes for which it was provided
and 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. Please note that we will only comply
with such erasure requests only to the extent it is legally obligated to, and depending on your
account activity until that date, certain personal data may be maintained in accordance with anti-
money laundering and counter-terrorist financing legislation or other obligations to which we
reasonably believe we are subject. Please note that if you request us to delete your information, we
may have to suspend the operation of your account and/or the products and services we provide to
you.
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 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. Please note that if you object to us processing
your information, we may have to suspend the operation of your account and/or the products and
services we provide to you.
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; (c) where you
need us to hold the data even if we no longer require it as you need it to establish, exercise or
defend legal claims; or (d) you have objected to our use of your data but we need to verify whether
we have overriding legitimate grounds to use it.
Request 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 process or where you provided us with this 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. We will advise you if this is the case at the time you withdraw your consent.
COOKIE POLICY
This cookie policy relates to your use of the Pharmacy App.
Cookies
cookie is a small text file which is placed onto your device when you use an app or visit a website.
We use the term cookies to also include other tracking technologies having equivalent or similar
effect, such as mobile device identifiers. We use cookies on the Pharmacy App to help us recognize
you and your device and store some information about your preferences or past actions. Cookies
support the integrity of our registration process, retain your preferences and account settings, and
help evaluate and compile aggregated statistics about user activity.
Our use of cookies
We may use cookies to:
recognise you whenever you use the Pharmacy App (this speeds up your access as you do not have
to log in each time);
obtain information about your preferences and use of the Pharmacy App ;
keep track of the services you are using;
carry out research and statistical analysis to help improve our content, products and services and to
help us better understand our users’ requirements; and
target our marketing campaigns and make them more relevant to your interests; and
make your online experience more efficient and enjoyable.
For further information on cookies generally visit
www.aboutcookies.org
or
www.allaboutcookies.org.
Types of cookies
There are two types of cookies:
Session cookies — these allow us to link your actions during a particular session. These expire each
time you close the Pharmacy App and do not remain on your device afterwards.
Persistent cookies — these are stored on your device in between sessions. These allow your
preferences or actions to be remembered. These will remain on your device until they expire, or you
delete them from your cache.
The cookies placed on your device fall into the following categories:
Strictly necessary cookies — these cookies are essential for the operation of the Pharmacy App and
for you to use its features. Without these cookies, services you have asked for could not be provided
Analytical/Performance cookies — these allow us to recognise usage patterns. This helps us to
improve the way the Pharmacy App works, for example, by ensuring that users are finding what they
are looking for easily. These cookies do not collect personally identifiable information about you. All
information collected by these cookies i is only used to improve how our App works
Functionality cookies — these cookies allow the Pharmacy App to remember the choices you make
(such as your user name, the region you are in and chosen preferences) and provide enhanced, more
personal features.
We may use the following 3rd party software frameworks that may store data on the device in our
iOS and Android apps:
Name and OS
The primary purpose
Branch (iOS and Android)
This allows the Pharmacy App to create deep links that work when downloading the application
from the App Store first.
Mixpanel (iOS and Android)
This enables us to monitor our audience size and usage pattern and send Pharmacy App
notifications.
Firebase (iOS and Android)
This enables us to monitor our audience size and usage pattern.
Appsflyer (iOS and Android)
This enables us to monitor our audience size and usage pattern.
Facebook (iOS and Android)
This enables us to allow users to register and login to the Pharmacy App with their Facebook account
and perform analytics and marketing campaigns on Facebook
Google Play services (iOS and Android)
Used for Google services e.g. Google Maps
Google Analytics (iOS and Android)
This enables us to monitor our audience size and usage pattern
Mailchimp, Sendgrid or Mailerlite
Used to provide email services to our users and keep track of usage
Please note that, throughout the Pharmacy App and on the Website, we may link to other websites
or applications owned and operated by certain trusted third parties. Some of these other third
parties may also use cookies – which are likely to be analytical, performance or targeting cookies –
or similar technologies, in accordance with their own separate cookie policies. For privacy
information relating to these third parties and cookies (over which we have no control) please refer
to their policies as appropriate.
How to exercise your right to refuse and/or to withdraw consent on the Pharmacy App
You have the right to refuse and/or to withdraw your consent for us to use cookies. Please note that
at this stage we are not providing users with the ability to customise preferences as to the use of
cookies on the Pharmacy App . Therefore, if you wish to refuse and/or withdraw your consent for us
to use cookies, you should stop using and accessing the App and its associated services and remove
the App from your device.
How to contact us
Please contact using the details contained in the Pharmacy App if you have any questions about this
cookie policy or the information we hold about you.