PharmaSwift Privacy Policy

Effective Date: 31 May 2025

At PharmaSwift, we are committed to protecting your privacy and the security of your Personal Information. This Privacy Policy explains how PharmaSwift Pty Ltd (ACN 683 211 314), ATF PharmaSwift Unit. ("PharmaSwift," "we," "us," or "our") collects, holds, uses, and discloses your Personal Information in relation to the PharmaSwift Platform.

PharmaSwift operates an online platform that connects individuals ("Users" or "you") with licensed Australian pharmacies ("Partner Pharmacies") for the convenient online ordering and delivery of medications and healthcare products. We understand the sensitive nature of health information and are dedicated to managing your data with the highest level of care and discretion.

This Privacy Policy has been developed in accordance with the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian Privacy Principles ("APPs").

Please read this Privacy Policy carefully to understand our practices regarding your Personal Information. By using the PharmaSwift Platform, you consent to the collection, use, and disclosure of your Personal Information as described in this policy.

1. Definitions

• "Personal Information" has the meaning given in the Privacy Act, which includes information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
• "Sensitive Information" is a sub-set of Personal Information and includes health information and if consented some biometric information. We primarily deal with sensitive information in the form of health information.
• "PharmaSwift Platform" refers to our website, mobile applications, and associated services that facilitate the ordering and delivery of medications and healthcare products.
• "Partner Pharmacy" means a licensed Australian pharmacy that has partnered with PharmaSwift to fulfil medication and healthcare product orders placed through the PharmaSwift Platform.
• "Delivery Partner" means a third-party logistics or delivery service provider engaged by PharmaSwift or a Partner Pharmacy to facilitate the delivery of orders to Users.

2. What Personal Information We Collect

We collect various types of Personal Information necessary to provide and improve the PharmaSwift Platform and services. This may include:

• Contact and Identification Information: Your full name, date of birth, gender, residential address, email address, and phone number.
• Account Information: Usernames, passwords, and other registration details.
• Payment Information: Billing address, credit card or other payment details (processed securely by third-party payment gateways.
• Health Information (Sensitive Information):
  • Prescription details (e.g., ePrescription tokens, medication names, dosages, dispensing instructions).
  • Medication history and current medication lists.
  • Nominated General Practitioner (GP) details.
  • Details of any allergies or adverse reactions.
  • Relevant health conditions or medical history that may impact medication dispensing or use.
• Order and Delivery Information: Details of products ordered, order history, delivery instructions, and delivery addresses.
• Communication Information: Records of your communications with us, Partner Pharmacies, or Delivery Partners, including customer support inquiries, feedback, and survey responses.
• Technical and Usage Information: Information about your device (e.g., IP address, device type, operating system, browser type), your activity on the PharmaSwift Platform (e.g., pages viewed, features used, time spent), and error logs.
• Marketing Preferences: Your preferences for receiving marketing communications.
• User-Generated Content: Any information you post or submit through the PharmaSwift Platform, such as reviews or testimonials.

3. How We Collect Personal Information

We collect Personal Information in several ways, including:

• Directly from You: When you register for an account, place an order, upload a prescription, interact with our customer support, complete forms, participate in surveys, or communicate with us through the PharmaSwift Platform.
• From Partner Pharmacies: When a Partner Pharmacy processes your order placed through the PharmaSwift Platform, they may provide us with information related to your dispensed medications and order status.
• From Healthcare Professionals: With your consent, your nominated GP or other healthcare provider may share relevant health information or ePrescription details with us or a Partner Pharmacy to facilitate your medication orders.
• From E-Prescription Systems: We may receive ePrescription tokens and associated details from authorised national e-prescription systems (e.g., My Health Record, Prescription Exchange Services) to allow Partner Pharmacies to dispense your medications.
• From Third-Party Service Providers: We may collect information from third-party service providers who assist us with identity verification, payment processing, or data analytics.
• Automatically: When you use the PharmaSwift Platform, we may collect technical and usage information through cookies, web beacons, and similar technologies (see Section 8 for more details).

4. Purposes for Which We Collect, Use, and Disclose Personal Information

We collect, use, and disclose your Personal Information for the following primary purposes:

• To Provide and Improve the PharmaSwift Platform and Services:
  • To register and manage your User account.
  • To process your medication and healthcare product orders.
  • To facilitate the dispensing of your prescriptions by Partner Pharmacies.
  • To arrange and manage the delivery of your orders through Delivery Partners.
  • To facilitate secure communication between you, Partner Pharmacies, and Delivery Partners.
  • To provide customer support and respond to your inquiries.
  • To verify your identity and ensure the legal and safe dispensing of medications.
  • To personalise your experience on the PharmaSwift Platform.
  • To develop, test, and improve our services, features, and functionality.
• For Communication:
  • To send you order confirmations, delivery updates, and important service-related notifications.
  • To communicate with you about your account, medications, and general health information.
  • To send you marketing and promotional communications (where you have opted-in).
• For Research and Analytics:
  • To understand how Users interact with the PharmaSwift Platform.
  • To conduct research, analysis, and statistical studies (often using de-identified or aggregated data) to improve our services and understand market trends.
• For Legal and Regulatory Compliance:
  • To comply with our legal obligations, including those related to healthcare regulations, consumer protection laws, and data privacy laws.
  • To prevent fraud, security breaches, and other prohibited or illegal activities.
  • To respond to lawful requests from government or law enforcement authorities.
  • To protect our rights, property, or safety, and that of our Users, Partner Pharmacies, or others.

5. Who We Disclose Your Personal Information To

To provide our services, we may disclose your Personal Information to the following third parties:

• Partner Pharmacies: To enable them to receive, review, dispense, and process your medication and healthcare product orders, including your prescription details and relevant health information.
• Delivery Partners: To facilitate the delivery of your orders, including your name, address, contact details, and specific delivery instructions.
• Healthcare Professionals: Your nominated GP or other relevant healthcare providers, where necessary and with your consent, to clarify prescription details or ensure continuity of care.
• E-Prescription Systems: We may interact with authorised e-prescription systems to retrieve and process your ePrescription tokens for dispensing by Partner Pharmacies.
• Payment Processors: Third-party payment gateway providers to process your payments securely.
• Third-Party Service Providers: Contractors and service providers who perform functions on our behalf, such as IT infrastructure, data hosting, analytics, customer support, marketing, and professional advisors (e.g., lawyers, accountants). These providers are obligated to protect your Personal Information.
• Related Entities: Our related bodies corporate within the PharmaSwift group, for internal business purposes, consistent with this Privacy Policy.
• Law Enforcement and Regulatory Bodies: Where required or authorised by law, or to protect our legal rights.
• Potential Purchasers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your Personal Information may be transferred as part of that transaction, subject to appropriate privacy safeguards.

We will not sell, rent, or trade your Personal Information to third parties for their independent direct marketing purposes without your explicit consent.

6. Direct Marketing

We may use your Personal Information (excluding Sensitive Information) to send you direct marketing communications about our services, promotions, or other information that we believe may be of interest to you. This may be via email, SMS, or other electronic means.

You can opt-out of receiving direct marketing communications from us at any time by:

• Following the unsubscribe instructions provided in the communication.
• Updating your preferences in your PharmaSwift account settings.
• Contacting us directly using the details in Section 13.

We will not use or disclose your Sensitive Information for direct marketing purposes without your express consent.

7. Quality of Personal Information

We take reasonable steps to ensure that the Personal Information we collect, use, and disclose is accurate, complete, and up-to-date. We rely on the information you provide to us, and we encourage you to:

• Notify us promptly of any changes to your Personal Information (e.g., change of address or contact details).
• Ensure that any prescription or health information you provide is accurate and current.

8. Security of Personal Information

We are committed to protecting your Personal Information from misuse, interference, loss, unauthorised access, modification, or disclosure. We implement a range of reasonable physical, technical, and administrative security measures, including:

• Encryption: Using industry-standard encryption for data in transit and at rest.
• Access Controls: Restricting access to Personal Information to authorised personnel who need it to perform their job functions.
• Secure Infrastructure: Storing data on secure servers and protected systems.
• Regular Audits: Regularly reviewing our security practices and systems.
• Data Minimisation: Collecting only the Personal Information necessary for our purposes.

While we strive to protect your Personal Information, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee absolute security. You are also responsible for maintaining the confidentiality of your account credentials.

9. Cookies and Other Technologies

The PharmaSwift Platform may use "cookies" and other similar technologies (such as web beacons, pixels, and local storage) to enhance your user experience, analyse site usage, and support our marketing efforts.

• Cookies are small text files stored on your device that allow us to recognise your browser or device and remember your preferences.
• We use cookies for:
  • Essential Functionality: To enable core functions of the PharmaSwift Platform (e.g., logging in, managing your cart).
  • Performance and Analytics: To collect information about how you use our Platform, allowing us to improve its performance and design.
  • Personalisation: To remember your preferences and provide a more personalised experience.
  • Advertising: To deliver relevant advertisements to you on and off the PharmaSwift Platform.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the PharmaSwift Platform may become inaccessible or not function properly.

10. Accessing and Correcting Your Personal Information

You have a right to request access to the Personal Information we hold about you and to request that we correct any inaccuracies.

• Access: You can generally access and update some of your Personal Information directly through your PharmaSwift account settings. For other information, or if you require a formal request, please contact us using the details below. We may need to verify your identity before providing access. In some cases, we may refuse access where legally permitted or required.
• Correction: If you believe that any Personal Information we hold about you is inaccurate, out-of-date, incomplete, irrelevant, or misleading, please contact us. We will take reasonable steps to correct it promptly. For certain health-related information, especially that originating from a Partner Pharmacy or your GP, we may advise you to contact the relevant healthcare provider directly for correction.

11. Making a Complaint

If you believe that we have breached the Privacy Act or the APPs, or if you wish to make a complaint about how we have handled your Personal Information, please contact us using the details below.

Please provide your name, email address, phone number, and a clear description of your complaint. We will acknowledge your complaint and respond to you as soon as practical, within 7 days.

If you are not satisfied with our response, you may have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make changes, we will update the "Effective Date" at the top of this policy and notify you of significant changes by posting a prominent notice on the PharmaSwift Platform or by emailing you. Your continued use of the PharmaSwift Platform after such changes constitutes your acceptance of the updated Privacy Policy.

13. Contact Us

If you have any questions about this Privacy Policy, our privacy practices, or wish to access or correct your Personal Information, please contact us at:

PharmaSwift Pty Ltd Email: privacy@pharmaswift.com.au

Important Note for PharmaSwift Operations:

Medications that are critical to your health or required to be taken on a strict schedule should be ordered well ahead of time. You should not rely on PharmaSwift for urgent or emergency deliveries. PharmaSwift is a platform that facilitates the ordering and delivery of therapeutic goods; it does not directly sell therapeutic goods. The dispensing and sale of medications are performed by our Partner Pharmacies.