User Data Policy

MedAdvisor's approach to protecting personal information

This app is “Powered by MedAdvisor” which is a provision of MedAdvisor International Pty Ltd (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 in the Privacy Act 1988 (Cth).

MedAdvisor handles the personal information of consumers who use the MedAdvisor Service and also handles the personal information of consumers who access the Service via the MedAdvisor Carer Mode.

'You' refers mainly to you as the person who is using our technology platform, which we call the MedAdvisor Service or the Service, to manage your own medications (or, if you are a caregiver using MedAdvisor Carer Mode, to manage the medications for the person under your care). 

Please read this User Data Policy carefully as it explains how MedAdvisor collects, holds, uses and discloses your information when you use the MedAdvisor Service, including how your information is used by pharmacies who use the MedAdvisor Service to manage their pharmacy services and patient information (MedAdvisor National Pharmacies).  A list of MedAdvisor National Pharmacies can be found here: https://www.mymedadvisor.com/find-a-pharmacy.  You can also look for the “MedAdvisor National Pharmacy” sticker, or other MedAdvisor promotional material in pharmacy.

Further information can be found in MedAdvisor's Privacy Policy (https://www.mymedadvisor.com/privacy), including information about how MedAdvisor uses third party service providers to assist us with running our business.  MedAdvisor's Privacy Policy also explains how you can request to access or correct the information that MedAdvisor holds about you, and how you can make a privacy complaint.

If there is any inconsistency between this User Data Policy and MedAdvisor's Privacy Policy, please refer to the information in MedAdvisor's Privacy Policy.

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 MedAdvisor National 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 National Pharmacy, in writing or electronically through the MedAdvisor Service), including where caregivers provide their own information or information of those they care for
• via any of our Apple iOS or Android applications (including pharmacy-group branded versions) or via our web portal at www.mymedadvisor.com (together, our Apps)
• via any MedAdvisor National 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 National 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 Nationals that you use to access our Apps to help us develop and secure our services, and
• we may use 'cookies' to store and sometimes track information about you in accordance with our Cookie Policy (available at www.mymedadvisor.com/CookiePolicy).
  
  

Types of personal information we collect

In order to use the MedAdvisor Service, you can register in person at a MedAdvisor National Pharmacy or directly through our Apps. The types of personal information we collect depends on the registration method you use and the level of account creation.  If the requested personal information is not provided, you will not be able to register an account or your account may have limited functionality.

The types of personal information we may collect are listed below. Your pharmacy may already have the information on file and may provide it to us when creating an account on your behalf:

• Your name, title, your date of birth and contact details (for example your email address and phone number);
  
  
• Your Medicare number and/or Department of Veterans Affairs (DVA) number;
  
  
• Medication, prescription and dispensing information, including historical information:
  • the MedAdvisor Service will collect information about prescriptions stored through the MedAdvisor Service and your prescribed medications and dispensing records when your prescription(s) is or has been dispensed at a MedAdvisor National 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 pharmacies that are not MedAdvisor National Pharmacies.  If you want your MedAdvisor Service to hold information about all your prescribed medications, you must fill them all through MedAdvisor National Pharmacies or input them yourself.  A list of MedAdvisor National Pharmacies can be found here: https://www.mymedadvisor.com/find-a-pharmacy.  You can also look for the “MedAdvisor National Pharmacy” sticker, or other MedAdvisor promotional material in pharmacy.
    
    
• Photographs and associated information:
  • If you register for the MedAdvisor Service remotely through one of our Apps, the following additional information may be collected:
    • 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 National 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 forward this information to your nominated MedAdvisor National 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.  Once confirmed, we will collect information about prescription(s) as outlined above.
    
    
• Other information:
  • your nominated MedAdvisor National Pharmacy;
  • additional information where you choose to provide or enter 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;
  • information that you link to or associate with your MedAdvisor account from other apps/websites or third party providers;
  • we may collect other information as part of the account creation process or in the use of our Apps, including usage data and passwords; and
  • 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 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 National 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 National 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 National 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 to run our business, including business development activities, 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 policy. 

We may, on a confidential basis, also disclose your personal information to your nominated MedAdvisor National Pharmacy (this includes providing any dispense data from our other MedAdvisor National Pharmacies that you use to your nominated MedAdvisor National 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 our App that is part of a pharmacy group that has a Pharmacy Branded MedAdvisor App, we may disclose the personal information we hold about you (but not any sensitive information about you) to the entity that operates the pharmacy group. 
If you use electronic prescriptions and/or the Tap-To-Refill service, your nominated MedAdvisor National 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.

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 National Pharmacy may also send you information about products and services that may be of interest to you. Your nominated MedAdvisor National 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 National Pharmacy.

Where your nominated MedAdvisor National Pharmacy is part of a pharmacy group, a reference in this 'Value-added messages' section to 'nominated MedAdvisor National Pharmacy' should be read as including a reference to the head entity of the pharmacy group that the nominated MedAdvisor National Pharmacy is part of. 

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.

Collection, uses and disclosures that are required or authorised by law

In certain situations MedAdvisor may be required or authorised by law to collect, use or disclose personal information for particular purposes. These may include situations where we are required or authorised to provide personal information to:

• government departments and agencies responsible for health; and
• Federal or State law enforcement agencies and investigative agencies, courts and various other Federal or State government bodies.

In these situations we will comply with the requirements of the Privacy Act 1988 (Cth) and the applicable laws when collecting, using or disclosing such information.

Research activities

We sometimes receive requests from research institutions, private companies and other third parties who wish to access data that we have collected through the MedAdvisor Service for research purposes. This may include data about MedAdvisor account holders and customers and patients of MedAdvisor National Pharmacies.

We consider such requests on a case-by-case basis, and we only provide data to such research projects where permissible under applicable laws (or where consent has been provided) and where we are satisfied that there are appropriate safeguards in place to protect the security, confidentiality and privacy of the relevant data.  These may include de-identifying and aggregating the data so that individual patients are not reasonably identifiable from the data.

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 (including to optimise and improve MedAdvisor’s services and solutions, and for other internal MedAdvisor uses). 

We also use de-identified data to provide analytics reports and statistical information to MedAdvisor National Pharmacies and our commercial partners (which include pharmaceutical companies that sponsor our programs). Any such reports and statistics are de-identified to ensure that patient personal information is not disclosed.

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 use de-identified data for research purposes, as described previously.

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):

• locations of users
• dispense records of prescriptions filled/not filled, and prescription filling behaviour and patterns that MedAdvisor Service users have been prescribed by their medical professional
• 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.

Accessing and correcting your personal information

You may contact our Privacy Officer (see the section “Resolving personal information concerns” below 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 within 30 days.

If you are a MedAdvisor account holder and you wish to delete your account, you may do so through the Apps.  If you have any difficulties, please contact us at support@medadvisor.com.au.  

If your account includes a MedAdvisor Carer Mode account, the details of the person(s) you are caring for will also be deleted.

Please note that the account deletion process may take up to 5 business days, and MedAdvisor may retain certain information as required or permitted by law.

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 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 update this User Data Policy from time to time.  We will use our best endeavours to notify users of the MedAdvisor Service when we make material changes to this User Data Policy. This may include displaying a notification on our software through which we provide the MedAdvisor Service or via email notification.