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Privacy Policy

MedAdvisor's approach to protecting personal information

MedAdvisor International Pty Limited (MedAdvisor, we, us, our) is committed to handling your personal information in a uniform, equitable and ethical manner. The protection of your personal information is something MedAdvisor takes very seriously. Personal information is information about you that identifies you or from which you are reasonably identifiable. MedAdvisor is bound by the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth).

Please take a moment to read our Privacy Policy as it describes what happens to your personal information  that is collected by our information technology platform, which we call the MedAdvisor Service or Service.

The MedAdvisor Service is defined as any software offered by MedAdvisor and accessed by consumers (consumers, patients or users) or pharmacy staff via our Apple iOS or Android application, in web format at www.mymedadvisor.com or via software installed in pharmacies, and any other software or documentation which supports the Service.

Our Privacy Policy is divided into three parts:

  • Part 1: MedAdvisor consumer users
  • Part 2: MedAdvisor pharmacies
  • Part 3: General provisions

Part 1 – MedAdvisor Consumer Users

Introduction

Part 1 of our Privacy Policy describes how MedAdvisor handles the personal information of consumers who use the MedAdvisor Service and also covers handling of the personal information of consumers who access the Service via the MedAdvisor Carer Mode.

In Part 1, 'you' refers mainly to consumer users of the MedAdvisor Service. Where appropriate, 'you' also refers to caregivers of consumer users where those caregivers are registered with the MedAdvisor Service.

Collection of your personal information

MedAdvisor will collect and hold your personal information in a fair and lawful manner, and not in an unreasonably intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you. However, when authorised we may collect personal information from third parties such as pharmacies participating in the MedAdvisor Service program (MedAdvisor Network
Pharmacies), your caregiver, and/or with your consent, from other health related apps/websites.

We may collect the personal information in a number of ways including through some of the following means:

  • when completing the registration process for the MedAdvisor Service and other related correspondence (whether in person at a MedAdvisor Network Pharmacy, in writing or electronically through the MedAdvisor Service), including where caregivers provide their own information or information of those they care for
  • via our website and apps
  • via any MedAdvisor Network Pharmacies that you deal with (the types of information we collect from such pharmacies is further outlined in the "Types of personal information we collect" section below)
  • while conducting customer satisfaction and market research surveys
  • in the course of supporting you either directly or through any MedAdvisor Network Pharmacies
  • when administering any of our services, and
  • as otherwise required to support or provide the MedAdvisor Service.

We may also collect personal information automatically through some of the following means:

  • we may receive location data passed to us from third-party services or GPS-enabled devices you have set up
  • we may collect information about how you use the Service to assist us to provide you with more tailored services, and to enable us to develop and improve our services
  • we may also collect information from the devices and networks that you use to access the App to help us develop and secure our services, and
  • we may use 'cookies' to store and sometimes track information about you, but only on an anonymous basis.

Types of personal information we collect

In order to use the MedAdvisor Service, you need to register in person at a MedAdvisor Network Pharmacy or remotely through our app. The types of personal information we collect on registration depends on the method you use. If you do not provide the required personal information set out below, you are able to continue to use the MedAdvisor Service but you won't be able to link your account to your nominated MedAdvisor Network Pharmacy which means the MedAdvisor Service will have limited functionality.

Registration at a MedAdvisor Network Pharmacy

To use our Service, you will need to provide us with at least your name, your email address and your date of birth and elect a password.
You may provide further information to allow us to tailor our services. This information can include (but is not limited to) your title, your gender; your postcode; your contact details including mobile phone number; and your address.
You will also need to provide certain information to the pharmacist, including your name and Medicare number. Typically, the pharmacy will already have these details on file in their pharmacy software system.
Once you sign up for the MedAdvisor Service, the pharmacist will create an activation code that is provided to you.

Once the activation code is provided to you by your pharmacist, you can use it to activate your MedAdvisor account, using either mobile or web App versions of MedAdvisor software.

At the point of activation you’ll be asked to enter your last name and date of birth and provide your email address (if not already provided), plus optionally to provide your mobile number. Your pharmacist may assist you to activate your MedAdvisor account on your mobile device, if time permits

MedAdvisor will never receive or hold your Medicare number under this process.

Remote registration

If you register for the MedAdvisor Service remotely through our app, you will need to provide us with:

  • your name, email address, Medicare number or Department of Veteran Affairs (DVA) number, date of birth and elected password;
  • a photograph of your Medicare card or DVA card, and your residential address so that we can match you to your file held by your MedAdvisor Network Pharmacy. We will also receive any other personal information on your Medicare card or DVA card; and
  • a photograph of yourself (or if you are a caregiver of a MedAdvisor consumer user, a photograph of the consumer user) holding photo identification with your name that matches your Medicare number. We will also receive any other personal information on that photo identification.

We may also collect other optional personal information as part of this process, including your gender.

We forward this information to your nominated MedAdvisor Network Pharmacy and they are responsible for confirming that your details match those on their file in their pharmacy software system after which, an activation confirmation message will be sent to you.


After registration

After you sign up, the MedAdvisor Service will only collect information about prescriptions stored through the MedAdvisor Service and your prescribed medications and dispensing records when your prescription(s) is dispensed at a MedAdvisor Network Pharmacy, including electronically through the MedAdvisor Service. This includes details of any prescriptions you store through the MedAdvisor Service, and the medication dispensed, dates dispensed, cost of medication and repeats left. MedAdvisor does not collect or hold information about your prescribed medications which you have filled at non-participating pharmacies. If you want your MedAdvisor Service to hold information about all your prescribed medications, you must fill them all through MedAdvisor Network Pharmacies. (Look for the “MedAdvisor Network Pharmacy” sticker, or other MedAdvisor promotional material in pharmacy).

The MedAdvisor Service may also collect information that you:

  • choose to enter into it, for example, in the optional health and medical profile on the application if you choose to complete the profile, or notes you may keep about each medication; and
  • link to or associate with your MedAdvisor account from other health related apps/websites.

In addition to the types of personal information identified above, we may collect personal information as otherwise permitted or required by law.

Our purposes for handling your personal information

As a general rule, MedAdvisor only processes personal information for purposes that would be considered relevant and reasonable in the circumstances. MedAdvisor will only collect information that is necessary for the purposes as described in this Privacy Policy, or other purposes specifically communicated to you. MedAdvisor uses fair and lawful methods to collect personal information.

MedAdvisor collects, holds, uses and discloses personal information to:

  • provide the MedAdvisor Service to you
  • provide you with services related to the MedAdvisor Service, such as prescriptions delivery and receipt, storage and processing of electronic prescriptions
  • enable you to access, and share information with, your nominated MedAdvisor Network Pharmacy for the purpose of assisting you in managing your MedAdvisor account and managing your medication use (also see the "Use and disclosure of your personal information" and "Value Added Messages" sections below)
  • ensure that only you, or those you authorise, are able to access your personal information
  • enable your nominated MedAdvisor Network Pharmacy to create a file in your name in their pharmacy software system if one does not already exist. This includes the disclosure of all personal information we collect under 'remote registration' to your MedAdvisor Network Pharmacy
  • with your consent, share the information stored on the MedAdvisor Service with any nominated medical practitioner or other health professional involved in your care
  • with your consent, enable optional access by a caregiver to the Service, via the MedAdvisor Carer Mode Consent Form or as otherwise authorised by you
  • assist you with a support query in connection with the MedAdvisor Service
  • comply with its legal and regulatory obligations, including to verify that the pharmacist confirmed your identity and matched it to an existing account in their pharmacy software system
  • otherwise provide the MedAdvisor Service in appropriate ways, and
  • contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.

Use and disclosure of your personal information

We may disclose your personal information to our employees, professional advisors or contractors to help us run our business and in connection with the purposes specified in the 'Our purposes for handling your personal information' section of this this Privacy Policy. Each of our employees, advisors and contractors is
bound by obligations of confidentiality and by the terms of this privacy policy.

We may, on a confidential basis, also disclose your personal information to your nominated MedAdvisor Network Pharmacy (this includes providing any dispense data from our other MedAdvisor Network Pharmacies that you use to your nominated MedAdvisor Network Pharmacy pharmacy) so that they can provide pharmacy, health and related services to you, including dispensing prescriptions.

If you have downloaded a pharmacy group branded version of the MedAdvisor application (Pharmacy Branded MedAdvisor App), or select a nominated pharmacy within the MedAdvisor app that is part of a pharmacy group that has a Pharmacy Branded MedAdvisor App, we may with your consent disclose the personal information we hold about you to the entity that operates the pharmacy group so that that entity can provide you with additional services (see the particular End User Licence Agreement for further details).

If you use electronic prescriptions and/or the Tap-To-Refill service, your nominated MedAdvisor Network Pharmacy will be sent information to enable them to fill your prescription before you arrive at the pharmacy. If you want to disclose information on the MedAdvisor Service to your doctor or pharmacist or anyone else,
you are free to do so. Please note, however, you are responsible for any breach of privacy that may arise from sharing your MedAdvisor account with others.

We may also use or disclose your personal information:

  • for the purposes for which we collected it;
  • for other purposes to which you have consented; and
  • as otherwise authorised or required by law.

De-identified information

We may use your personal 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.

Where you use the MedAdvisor Service (or any Pharmacy Branded MedAdvisor App) in relation to pharmacies that are part of a pharmacy group, we may disclose your
information (including prescription and dispense data) in de-identified form to the entity that operates that pharmacy group. We may also provide de-identified information drawn from the MedAdvisor Service in aggregated form, to third parties. This information may include (but is not limited to):

  1. locations of users
  2. dispense records of prescriptions filled/not filled, and prescription filling behaviour and patterns that MedAdvisor Service users have been prescribed by their medical professional, and
  3. functions accessed by users including analytics of use of the MedAdvisor Service.

When referring to the use of 'aggregate data', this means the aggregate of data composed of at least 10 or more patient records.
When your personal information is included in de-identified data, or de-identified aggregated data, it is not reasonably possible to identify you or anything about you from that data. We may use your de-identified data to offer services such as sending automatic messages to you with training and medication specific information relating to your current prescription. This service will be offered to you with an option of opting-out of these communications and additional services.

Value-added messages

We may provide you with information such as tips, advice and warnings about your prescribed medications. We may also provide you with invitations to participate in medical research relevant to the medications you are taking. We will not disclose your personal information to third parties for marketing purposes.

You may opt out at any time if you no longer wish to receive commercial messages generally or about any specific prescribed medication. You can make this request by contacting our Privacy Officer. You will be offered an option to “opt-out” of any such messaging along with each message, and generally for each medication.

As part of the MedAdvisor Service, your nominated MedAdvisor Network Pharmacy may also send you information about products and services that that may be of interest to you. Your nominated MedAdvisor Network Pharmacy may elect to disclose your personal information (such as your contact details) to us to the extent required to allow the pharmacist to submit claim forms to relevant government bodies via the
MedAdvisor Service for any such products and services they provide to you (for example, so that the pharmacist can receive payment for dispensing Pharmaceutical Benefits Scheme medicines to you). You can opt out at any time from receiving information sent by your nominated MedAdvisor Network Pharmacy.


Part 2 – MedAdvisor Pharmacies

Introduction

Part 2 of our Privacy Policy describes how MedAdvisor handles data collected and stored for participating MedAdvisor Network Pharmacies, their patients, and the staff of those pharmacies.
Part 1 of our Privacy Policy applies equally to our handling of the personal information of pharmacists and other staff at participating pharmacies, and other individuals from whom we may collect personal information in the course of our business from time to time (such as our suppliers, job applicants and contractors), except for those passages in Part 1 that clearly relate only to patient users.


Collection of personal information of pharmacy staff

We may collect basic contact information of pharmacy staff in the course of providing the MedAdvisor Services to your pharmacy and its patients. Basic contact information may include the name, role, email address, postal address or phone numbers of pharmacy staff. Where requested, supply of such information is
optional but can assist us in providing better support and training services to your pharmacy.


Use and disclosure of personal information of pharmacy staff

We will only use contact information of pharmacy staff for the purposes of providing the MedAdvisor Service to your pharmacy and patients, and in supporting and training on the use of MedAdvisor by your pharmacy staff.

We will not pass on staff contact information to others, except where a pharmacy staff member (or other individual) has completed a ‘Registration of Interest’ form on our website or emailed us a query regarding the MedAdvisor Service. In such situations we reserve the right to pass on the contact information supplied
to our distributors and partners, particularly to assist us in responding to such queries.


Collection of patient data from your pharmacy’s patients

As outlined in Part 1 of this document, the MedAdvisor System collects, stores and utilises patient data for the purposes detailed in Part 1.

MedAdvisor does not sell patient personal information and any sharing of patient data is strictly limited to the purposes listed in Part 1.


Part 3 - General Provisions

The following provisions apply generally to all personal information we collect, hold or otherwise deal with in our business, including to MedAdvisor consumer users and MedAdvisor pharmacy staff:

Accessing and correcting your personal information

You may contact our Privacy Officer (see Part 3 of this policy for contact details) to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to any of the personal information about you held by us.

MedAdvisor is not obliged to correct any of your personal information if it does not agree that it requires correction and may refuse to do so. If MedAdvisor refuses a correction request, we will provide you with a written notice stating our reasons for refusing.


Deleting your personal information

If you apply remotely to register for the MedAdvisor Service, we will promptly delete or permanently de-identify the personal information you provide to us in that process if your nominated MedAdvisor Network Pharmacy rejects the application or fails to review your application within 30 days.

If you no longer wish to use the MedAdvisor Service, you may opt-out of the Service by requesting the cancellation of your use of the Service to our Privacy Officer (see Part 3 of this policy for contact details) and your personal information will be deleted or de-identified permanently.


Protection of personal information

MedAdvisor maintains appropriate physical, procedural and technical security for its offices and information storage facilities so as to prevent any misuse, interference or loss, or unauthorized access, disclosure, or modification of personal information. This also applies to disposal of personal information.

MedAdvisor further protects personal information by restricting access to personal information to those who need access to do their job (for example, to respond to your queries or provide you or your pharmacist/pharmacy with support services in relation to the MedAdvisor Service).

Overseas transfers of personal information

We do not disclose, store or transmit any of your personal information outside Australia.

Resolving personal information concerns

If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your personal information, please email our Privacy Officer at: privacy@medadvisor.com.au

Once a complaint has been lodged, the Privacy Officer will respond to you as soon as possible.

You may also lodge a complaint with the Office of the Australian Information Commissioner by telephone: 1300 363 992 or email: enquiries@oaic.gov.au

Changes

We reserve the right to change the terms of this Privacy Policy from time to time. We will use our best endeavours to notify users of the MedAdvisor Service when we make material changes to our Privacy Policy.

This may include displaying a notification on our software through which we provide the MedAdvisor Serviceor via email notification. An up-to-date copy of our Privacy Policy is available at: www.mymedadvisor.com/privacy.

This Privacy Policy was last updated on 10 September 2020.