Privacy and Cookie Policy

This Privacy & Cookie Policy covers two separate things. Part 1 explains how PharmacyConnect handles your information on this website (pharmacyconnect.ie). Part 2 is the privacy and cookie policy for the Pharmacy App that a pharmacy publishes on the PharmacyConnect platform — where your pharmacy, not PharmacyConnect, is the data controller. Please read the part that applies to you.

Who we are

PharmacyConnect (“we”, “us”, “our”) is a trading name of Village Financial Limited, a company registered in Ireland with its registered office at Duncairn House, Victoria Road, Greystones, Co. Wicklow, A63 N9V0. Village Financial Limited is the data controller for personal data collected through this website, pharmacyconnect.ie. If you have any questions about this policy or how we handle your data, you can contact us by email at hello@pharmacyconnect.ie or by phone on +353 1 525 3325.

What we collect

When you use this website we may collect:

• Digital Health Check details — the answers you give in the questionnaire, including your pharmacy name, whether you’re a single pharmacy or a group and how many branches, the state of your current website, whether you offer online ordering, booking and CCS/vaccination services, your rough daily call volume, your PMR system, how you handle reimbursement, your priorities and rough timeline, and any frustrations you tell us about.
• Your contact details — the name, job title, role in the decision, email address and phone number you provide so we can send your report and follow up.
• Messages you send us — anything you include when you contact us by email or through the site.
• Consent record — whether you agreed to us contacting you about your Digital Health Check.
• Technical and usage data — your IP address, browser and device type, and how you use the site. See ‘Cookies on this website’ below.

How we use your information

We use your information to:

• prepare and send your personalised Digital Health Check report, and contact you about it;
• respond to your enquiries and provide the information or services you ask for;
• send you marketing about PharmacyConnect where you have agreed to receive it;
• operate, secure, maintain and improve this website; and
• comply with our legal and regulatory obligations.

We rely on the following legal bases under the GDPR: your consent (for example, to contact you about your Digital Health Check or to send marketing); our legitimate interests in running and promoting our business and keeping the site secure, where these are not overridden by your rights; taking steps at your request before entering a contract; and compliance with a legal obligation. We do not sell your personal data.

Cookies on this website

A cookie is a small text file stored on your device. On this website we currently use strictly necessary cookies only:

• Cookie choice — a small record of whether you accepted or declined optional cookies, so we can remember your preference and show the banner again only when needed.
• Admin session — if you are a signed-in administrator, a session cookie that keeps you logged in. This does not apply to ordinary visitors.

We do not currently run analytics or any other non-essential cookies on this website. If we introduce optional analytics in the future, it will be described here and will run only if you accept it in the cookie banner — it stays switched off unless you do. You can change your choice at any time by clearing this site’s data in your browser, which will show the banner again on your next visit.

Who we share it with

We share your information only with service providers who help us run the website and deliver your Digital Health Check, acting as our processors under contract. These include our hosting provider and our email delivery provider. We may also disclose information where we are required to by law, or to establish, exercise or defend legal claims. We do not share your data with third parties for their own marketing without your explicit consent.

Where your data is stored

Your submission data is stored securely in a database hosted on our infrastructure provider (Railway) within the EU/EEA. Where any provider processes data outside the EEA, we rely on an appropriate safeguard such as an EU adequacy decision or the European Commission’s Standard Contractual Clauses.

How long we keep it

We keep Digital Health Check submissions and enquiry data for up to 24 months so we can follow up with you and for our legitimate business records, after which we delete or anonymise it — unless we need to keep it longer to meet a legal obligation or to establish, exercise or defend a legal claim.

Your rights

Under the GDPR you have the right to access your personal data, to have it corrected or erased, to restrict or object to how we use it, to data portability, and to withdraw consent at any time (without affecting processing carried out before you withdrew it). To exercise any of these rights, contact us at hello@pharmacyconnect.ie.

How to contact us and complaints

For any privacy question, or to exercise your rights, contact us using the details above. You also have the right to complain to the Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland (dataprotection.ie).

PharmacyConnect Privacy and Cookie Policy

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.

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.

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 the 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, 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. 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 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, 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 within 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 (Pharmacy App)

We use tracking technologies such as cookies to distinguish you from other users of 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, 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.

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 by 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

We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes outlined above.

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 ‘Which purposes will we use your personal data for’ 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 you have requested, including our Payment Service Provider (PSP), correspondent banks, and market analysis service providers;
• Agencies providing identity verification and other fraud and financial crime prevention services to undertake required verification checks and help fight financial crime, including fraud, Anti-Money Laundering and Terrorist Financing;
• Other financial institutions and third parties where we are required 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;
• 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, assignment of rights or obligations, or a sale or acquisition, provided that any recipient uses your information for the same purposes as it was originally supplied to or used by us;
• Regulatory and law enforcement authorities, whether outside or inside 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; or
• Where we use certain service providers, we may use specific contracts approved by the European Commission (Standard Contractual Clauses) which give personal data the same protection it has in Europe.

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 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.

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 the ‘Your legal rights’ section below. 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 (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 there is no good reason for us continuing to process it, where you have successfully objected to processing, where we may have processed it unlawfully, or where we are required to erase it to comply with local law. We will only comply with such requests to the extent we are legally obligated to; certain personal data may be maintained in accordance with anti-money laundering and counter-terrorist financing legislation or other obligations. If you request us to delete your information, we may have to suspend the operation of your account and/or the services we provide to you.

Object to processing where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object, and where we are processing your personal data for direct marketing purposes. In some cases we may demonstrate compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend processing in certain scenarios, for example to establish the data’s accuracy, or where our use is unlawful but you do not want it erased.

Request transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to process or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. 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.

Cookie Policy (Pharmacy App)

This cookie policy relates to your use of the Pharmacy App. A 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 recognise you and your device and store some information about your preferences or past actions.

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;
• 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.

Session cookies — these allow us to link your actions during a particular session. They expire each time you close the Pharmacy App and do not remain on your device afterwards.

Persistent cookies — these are stored on your device between sessions and allow your preferences or actions to be remembered until they expire or you delete them from your cache.

Strictly necessary cookies — 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 and help us improve the way the Pharmacy App works.

Functionality cookies — these allow the Pharmacy App to remember the choices you make and provide enhanced, more personal features.

We may use the following third party software frameworks that may store data on the device in our iOS and Android apps: Branch (deep links), Mixpanel (audience and usage analytics and notifications), Firebase (audience and usage analytics), Appsflyer (audience and usage analytics), Facebook (register/login and marketing analytics), Google Play services (Google services such as Maps), Google Analytics (audience and usage analytics), and Mailchimp, Sendgrid or Mailerlite (email services). Some of these third parties may also use cookies in accordance with their own separate cookie policies, over which we have no control.

How to exercise your right to refuse and/or withdraw consent on the Pharmacy App

You have the right to refuse and/or to withdraw your consent for us to use cookies. 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, you should stop using and accessing the App and its associated services and remove the App from your device.

How to contact us (Pharmacy App)

Please contact us using the details contained in the Pharmacy App if you have any questions about this cookie policy or the information we hold about you.