This Privacy Policy explains how Pharma Online Limited (“PHARMA’) collects, uses, store, transfers, erases and destroys Personal Data that we collect from our customers who have enrolled in the Pharma Online Program (“Program”) via the Software in order to utilize the Pharma Services.

1. Definitions

1.1          ‘Personal Data’ means: – 

• any information (however stored) relating to a living individual or an individual who has been deceased for less than thirty (30) years who can be identified

1. from the information alone; or
2. from the information and other information in the possession of, or likely to come into the possession of PHARMA; or

• Any information (however stored) pertaining to the health record of a living individual or an individual who has been deceased for less than thirty (30) years which-

1. is in the custody or control of a health professional in connection with the care of an individual; and
2. consists of information relating to-
3. i) The past or present physical or mental health, or condition, of an individual, for example,
4. A) clinical information about diagnosis and treatment;
5. B) genetic data or biometric data;
6. C) information about the testing of any body part or bodily substance, or the donation of a body part or bodily substance;
7. ii) the registration of an individual for the provision of health services and any number, symbol or code assigned to uniquely identify the individual for those services;

iii) the name of the individual’s health care provider;

1. iv) payments made by, or the eligibility of, the individual for the provision of health services, or any other health related information about the individual that is collected in the course of the provision of health services to that individual;
   • ‘Services’ mean health related services which include but are not limited to the following:-
2. Creation of an online account via a mobile application software or a web login;
3. Provision of electronic health record services which include uploading, storing, and accessing health records electronically;
4. The transmission of health records electronically between medical practitioners;
5. The transmission of health records between a medical practitioner and a Pathology/Radiology Lab;
6. Provision of e-prescription services, in particular, facilitating and coordinating the generation and transmission of electronic prescription data from medical practitioners to pharmacies for the fulfilment of prescriptions; and
7. Generation of anonymous statistical reports;
   • ‘Software’ means the mobile application, website, platform or systems developed and maintained by PHARMA for the purposes of carrying out the Services;
   • ‘Third-Party Health Service Provider’ means any person i.e. individual or entity who has entered into an agreement with PHARMA including any Pathology/Radiology Lab, Pharmacy or medical practitioner to provide the Services; and
   • ‘Third-Party Supplier’ means any person i.e. individual or entity who PHARMA has engaged to provide the Services;

2. Types of Personal DATA

2.1 This Privacy Policy explains our practices with regard to Personal Data collected by PHARMA for its own business purposes. We may collect the following types of Personal Data:

• Contact Information that allows us to communicate with you which include but is not limited to your name, D.O.B., username, mailing address, telephone numbers, email address or other addresses that allow us to send you messages.
• Relationship Information that helps us do business with you, such as the types of products and services that may interest you.
• Transaction Information about how you interact with PHARMA including inquiries, online account information, and information about how you use the Software.
• Health information for the purposes of providing the Services to you such as any information concerning past or present physical or mental health or condition, clinical information about diagnosis and treatment, genetic data or biometric data.

2.2 The above is a non-exhaustive list which is reflective of the varied nature of the Personal Data processed as part of providing the Services.

3. How PHARMA collects Personal DATA

3.1  In many cases, we will collect Personal Data directly from you. We will ask you for Personal Data (including Contact Information, Health Information and Relationship Information) when you interact with us, such as when you create an online account and enroll in the Program via the Software. We may collect additional Relationship Information from third party data suppliers who enhance our files and help us better understand our customers. We will also collect Transaction Information when you interact with us, such as when you create an online account and enroll in the Program via the Software.

3.2 We will use cookies and other technological tools to collect information about your use of the Software.

4. How PHARMA uses Personal Data

PHARMA will use your Personal Data to:

• Create an online account for the purposes of enrolling you in the Program and facilitating the use of the Services by you;
• Provide you with the Services;
• Provide you with marketing communications and offers for additional products and services from PHARMA;
• Administer surveys and other promotional events;
• Generate anonymous statistical reports; and
• Manage our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, forum management, fulfillment, analytics, security and fraud prevention, corporate governance, reporting and legal compliance, and business continuity.

5. Why Personal Data is disclosed by Pharma

 PHARMA understands that you do not want us to provide your Personal Data to third parties for their own marketing purposes. We will limit our sharing of your Personal Data as follows:-

• We may share your Personal Data with an affiliate or associated entity of PHARMA, which may only use your Personal Data for the purposes listed above.
• We may also share your Personal Data with a Third-Party Health Service Provider or a Third-Party Supplier, who will be bound by law or contract to protect your Personal Data and only use your Personal Data to facilitate the use of the Services by you  PROVIDED HOWEVER THAT in circumstances where your Personal Data is transferred to a territory outside of Jamaica, such territory may not provide for an adequate level of data protection as granted in Jamaica. It will be our obligation to alert you that the need may arise for us to transfer your Personal Data to a territory outside of Jamaica. We will obtain your consent for such transfer of Personal Data and you shall not hold us liable for the manner in which your Personal Data is held or processed by any third parties which are situated outside Jamaica.
• We may also disclose Personal Data where needed to enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will also always disclose Personal Data when required to do so by law.
• Please note that we may also use and disclose information about you that is not personally identifiable. For example, to generate reports that contain aggregated and statistical data about our clients. These reports do not contain any information that would enable the recipient to contact, locate or identify you.

6. Cookies and Other Data Collection Technologies

6.1 When you use our Software, we will collect certain Transaction Information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons. For example, when you visit our website, we will place cookies on your computer. Cookies are small text files that websites send to your computer or other internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available.

6.2 We may collect many different types of information from cookies and other technologies. For example, we may collect information from the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address assigned to the device you use to connect to the internet. An IP address is a unique number that devices use to identify and communicate with each other on the internet. In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Data. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns.

6.3 In some cases, we do associate the information we collect using cookies and other technology with your Personal Data. This Privacy Policy applies to the information when we associate it with your Personal Data.

6.4 PHARMA has relationships with third party advertising companies to place advertisements on this website and other websites, and to perform tracking and reporting functions for this website and other websites. These third party advertising companies may place cookies on your computer when you visit our website or other websites so they can display targeted advertisements to you. These third party advertising companies do not collect Personal Data in this process, and we do not give any Personal Information to them as part of this process. However, this Privacy Policy does not cover the collection methods or use of the information collected by these vendors. You can opt out of being targeted by many third party advertising companies by visiting [www.daisy-health.com].

7. Mobile Application

PHARMA’s mobile application will allow you to access your online account, utilize the Services, interact with us online and receive other information via your smartphone. All Personal Data collected by PHARMA via our mobile application is protected by the terms of this Privacy Policy.

8. Your Choices

You can always limit the information you provide to PHARMA. You can also limit the communications, if any, that PHARMA sends to you. To opt-out of commercial emails, if any, simply click the link labeled “unsubscribe” at the bottom of any email we send you. Please note that even if you opt-out of promotional emails, we may still need to contact you with important Transactional Information about your online account. For example, even if you opt-out of emails, we may still send you activity confirmations. If you have any questions about your choices or if you need any assistance with opting-out, please contact Data Privacy contact set out in this Policy below.

9. WHAT ARE YOUR RIGHTS WITH RESPECT TO DATA PROTECTION

9.1 You will have the following rights with respect to your Personal Data:

• Access: You are entitled to ask PHARMA if we are processing your Personal Data and, if we are, you can request access to your Personal Data.  This enables you to receive a copy of the Personal Data we hold about you and certain other information regarding the Personal Data;
• Rectification: You are entitled to request that any incomplete or inaccurate Personal Data PHARMA hold about you is rectified. If you are entitled to rectification and if we have shared your Personal Data with others, we will notify them about the rectification where possible. If you make such a request, where possible and lawful to do so, we will also tell you who we have shared your Personal Data with so that you may contact them directly.
• Erasure: You are entitled to ask PHARMA to delete or remove Personal Data in certain circumstances such as where we no longer need it or if you withdraw your consent (where applicable). There are also certain exceptions where PHARMA may refuse a request for erasure, for example, where the Personal Data is required for compliance with local laws or in connection with claims. If you are entitled to erasure and if PHARMA have shared your Personal Data with others, we will notify them about the erasure where possible.
• Restriction: You are entitled to ask PHARMA to suspend the processing of your Personal Data, for example, if you would like for us to establish its accuracy or the reason for processing it;
• Transfer: You may request that PHARMA transfers certain of your Personal Data to another party;
• Objection: You are entitled to ask PHARMA to stop processing your Personal Data in certain circumstances, for example, where the processing is likely to cause substantial damage or distress except if we can demonstrate compelling legal grounds for the processing. You also have the right to object where PHARMA is processing your Personal Data for direct marketing purposes. You may opt-out of receiving direct marketing from PHARMA at any time.
• Automated decisions: You may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.
• Consent: If PHARMA relies on your consent (or explicit consent) as our legal basis for processing your Personal Data, you may withdraw your consent at any time. However, we note that this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, PHARMA may not be able to provide certain Services to you. We will of course advise you, if this is the case, at the time you withdraw your consent.

9.2 Please note that some of these rights may be limited where PHARMA has an overriding interest or legal obligation to continue to process your Personal Data.

9.3 If you would like to exercise any of the abovementioned rights, you may contact the Data Privacy contact set out in this Policy below.

10. CORRECTING AND UPDATING PERSONAL DATA

10.1 You must inform us immediately where your Personal Data has changed, or where you believe that   the Personal Data we hold is inaccurate, incomplete or otherwise deficient. You can log into your online account at any time to access and update the information you have provided to us.

10.2 PHARMA will not be held responsible for any loss that may arise due to us having any inaccurate, incomplete, or otherwise deficient Personal Data which you have provided to us.

11. Information Security

PHARMA has implemented an information security program that contains administrative, technical and physical controls that are designed to safeguard your Personal Data. For example, we use industry standard encryption technology to secure sensitive Personal Data when it is being collected and transmitted over the internet as well as firewalls, site monitoring and intrusion detection software. Please note that you should also take steps to protect your Personal Data. PHARMA, however, does not make any representations or warrants that your Personal Data may not be accessed, disclosed, altered, or destroyed by breach of such safeguards. PHARMA will notify you immediately in the event of a security breach and will maintain an incident response policy that includes notifications consistent with applicable law.

12. Changes to this Privacy Statement

From time to time, we may update this Privacy Policy to reflect new or different privacy practices. We will place a notice on our website  when we make material changes to this Privacy Policy. Additionally, if the changes will materially affect the way we use or disclose previously collected Personal Data, we will notify you about the change by sending a notice to the primary email address associated with your online account. However, we encourage you to review this Privacy Policy periodically to be informed of how we use their Personal Data.

13. RETENTION OF PERSONAL DATA

PHARMA will retain your Personal Data only for as long as we have a valid business purpose and in accordance with applicable laws.

14. APPLICABLE LAW

      This Privacy Policy shall be governed by and construed in accordance with the laws of Jamaica.

15. How to Contact Us

 Please contact us if you have any questions or comments about our privacy practices or this Privacy Policy. Our contact information are as follows:

Email Address: info@daisy-health.com

Telephone Number: 1-888-429-5765