Privacy Policy

Introduction

This policy (together with our end-user licence agreement (EULA) and any additional terms of use incorporated by reference into the EULA, together our “Terms of Use”) applies to your use of:

• PharmAppy mobile application software (available on a number of different App marketplaces (the “App Sites”)), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (“Device”) and PharmAppy Web Application (collectively “App”); and
• any of the services accessible through the App (“Services”) that are available on the App Site or other sites of ours (“Services Sites”), unless this policy or the EULA states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.

Important information and who we are

PharmAppy Services Limited is the controller and is responsible for your personal data (collectively referred to as “PharmAppy”, “we”, “us” or “our” in this policy).

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

• Full name of legal entity: PharmAppy Services Limited
• Email address: [email protected]
• Postal address: 3rd Floor 86-90 Paul Street, London, United Kingdom, EC2A 4NE

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

Please note that while the App is provided by PharmAppy, this privacy policy refers not only to the services which we provide but also to the patient services delivered by your pharmacy (the “Pharmacy”), such as receiving and fulfilling your repeat prescriptions.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

For the avoidance of doubt, by registering, or using, or supplying data or information through the App, you are aware of the collection, use and transfer of that data and your information under the terms of this privacy policy (and in addition you acknowledge that the use of your data by the Pharmacy will also be subject to the terms of their privacy policy, which they will bring to your attention at the relevant time).

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 15/05/2025. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data collected about you

We (and the Pharmacy) will collect and process the following type of personal data (and the data further detailed in the “Use of your information by us (and by the Pharmacy)”) section below about you:

Information you provide (“Submitted Information”)

You may give us information about you by filling-in forms on the relevant App Site, within the App itself or by corresponding with us (for example by email to report a problem) or with the Pharmacy. This class of information includes:

• information you provide when you download, register or use the App or subscribe to any of the Services. This may include your first name, last name, date of birth, email address and phone number, home address, password and other registration information and your chosen GP surgery and Pharmacy. It also includes personal information which relates to specific topics which are thought to be more privacy sensitive (e.g. information about your health). (the “Registration Data”);
• details of your medication, and your dependant's and / or family members' medication, including name, dosage, dosing schedule and any requests or orders which you submit to order medication (including repeat medications) from the Pharmacy (the “Medicines Data”); and
• information you provide via any social media functions on the App, when entering any competition, promotion or survey, or if providing any feedback regarding the App or the Services (“Feedback Data”)

Information we collect about you and your device

Each time you use the App we will automatically collect the following information:

• technical information, including the type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system, and time zone setting (“Device Information”).
• Details of your use of the App (“Log Information”); and
• Details of your location — We use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings (“Location Information”).
• Wearable Health Data — If you choose to enable this feature, we may collect and process data from connected health platforms such as Apple Health, Google Fit, Fitbit, or other wearable sources. This may include:
  • Resting Heart Rate (RHR)
  • Heart Rate Variability (HRV)
  • Blood Oxygen Saturation (SpO₂)
  • Step count and physical activity
  • Sleep duration

  This data is used to help identify early signs of changes in your health trends and to provide personalised recommendations or prompts to book appropriate services at your pharmacy.

• Information we collect when you make an order for paid products and/or services including payment card details (“Financial Data”). Any Financial Data that is collected by Stripe is subject to Stripe's privacy policy and is not governed by this privacy policy. Stripe's privacy policy can be located at https://stripe.com/privacy.

If you contact us, we may keep a record of that correspondence.

Use of your information by us (and by the Pharmacy)

The relevant data privacy legislation describes the person that determines the purposes for which, and the manner in which, personal data is processed as the ‘data controller’ and it is the data controller that is primarily responsible for ensuring that the relevant personal data is processed properly and legally. More than one person is capable of being data controller in respect of the same personal data and each is responsible for its use of that data.

As we are supplying and operating the App and it is the Pharmacy which is delivering patient services to you (i.e. by fulfilling your prescriptions, repeat prescriptions, pharmacy service requests, providing appointments) both of us are acting as data controllers in relation to certain elements of your personal data, in particular:

• both we and the Pharmacy are data controllers in respect of the Registration Data (as defined above);
• we will be the data controller in respect of any Feedback Data provided to us; and
• the Pharmacy will be the data controller in respect of the Medicines Data (as defined above).

This privacy policy sets out the basis on which the personal data we collect from you, or that you provide, will be processed by us and the basis on which it will be provided to the Pharmacy. Processing of your personal data undertaken by the Pharmacy will be determined by the Pharmacy and will be subject to the terms of the Pharmacy's own privacy policy and terms which it will make available to you.

We and/or the Pharmacy (as appropriate) may use the information held about you in the following ways:

• Device Information: We will use this information to ensure that we present the correct version of our App for your device. We will store information about the currently installed mobile operating system and its version, mobile application version and brand of your device to help identify and fix reported issues.
• Registration Data: We and/or the Pharmacy (as appropriate) will use information which you submit as part of registering to use the App in order to manage your account with us or with the Pharmacy (as appropriate), to provide the Services and for our own respective internal administrative purposes.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and/or the Pharmacy (as appropriate) and your communication preferences.
• Medicines Data: We will transfer the Medicines Data which you submit to your Pharmacy. The Pharmacy will use the Medicines Data for the purposes of providing pharmacy services to you. As the App is facilitating the transfer of information regarding your healthcare between us and the Pharmacy we will process that data in accordance with their instructions as required to provide the Services to you.
• The Pharmacy may send a message to you using the App to say if it can fulfil your order and, if so, if the order will be delivered or made available for collection.
• You may be asked to show some identification by the Pharmacy when you collect your prescription.
• The Pharmacy may also wish to use this data (together with the relevant Registration Data) for the purposes of targeted advertising of products and services offered by the Pharmacy, other companies within the Pharmacy's group of companies and operators of pharmacies operating under the same brand as the Pharmacy. If the Pharmacy wishes to use your data for any direct marketing purposes then it will detail its use of the same in its privacy policy. Note that information about the order you place with the Pharmacy is stored by us centrally. The App stores information about used pills if you decide to use the ‘Pills Reminder’ feature; this data is only stored locally on your device and is not sent to us or the Pharmacy. We may need to access this information from time to time on behalf of the Pharmacy in order to provide support and maintenance services in respect of the App.
• Log Information: if you are using an Android device then we will collect information regarding your use of the App to help us to understand what functionality is most used and to help us enhance these functionalities to improve the user experience.
• Location Information: GPS location functionality on your device (if any) may (if you select the relevant options) be used to determine your current location so as to identify nearby medical services. Your location details are not stored either within the App or otherwise by us but may be provided to the relevant map providers (Google and Apple) where its use will be subject to the relevant provider's privacy policy.
• Third Party Information: the App does not retrieve information about you from any third party services.
• For security and safety purposes: We will monitor activity in order to help protect our users from security threats and to detect if users are trying to misuse any element of the App or Service or to use them in an unauthorised manner. We may also use your contact information in order to alert you to any relevant security issues or safety concerns of which we are aware.
• To statistically analyse behaviour and activity: We will monitor user interest and behaviour to help us to understand general usage of the Services and the App to help us improve the services we provide. We may conduct statistical analysis in respect of the Services either ourselves or through an agency acting on our behalf.
• To monitor changes in your wearable health data (if you enable this feature) and to provide personalised health insights, or reminders. These insights may be used to prompt you to take further action, such as taking a blood pressure reading or booking a pharmacy service.

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.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

Purposes for which we will use your personal data

By choosing to provide us with Medicines Data or health data from your wearable device or connected health platform (such as Apple Health, Fitbit or Google Fit), then to the extent that such data amounts to ‘special category data’, you are expressly consenting to our processing of that data for the purposes of delivering the Services as outlined in this privacy policy and the EULA.

This may include data such as resting heart rate, heart rate variability, blood oxygen saturation, activity levels, and sleep data, which we may use to help identify changes in your health and provide you with relevant prompts or service recommendations. You may withdraw your consent for this at any time by disabling ‘Wearable Permissions’ in the ‘Account’ tab of the App.

Disclosures of your personal data

We and/or the relevant Pharmacy (as appropriate) may disclose your personal information to third parties:

• If we or the Pharmacy (or both) are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
• To the Pharmacy for the provision of the repeat prescription service and pharmacy service booking facility;
• To a contractor appointed by us to deliver elements of the App or the Services on our behalf;
• For administration of your PharmAppy App account;
• Other trusted third parties, who will receive it as data controllers in their own right (such as auditors, consultants and legal advisers). In such cases, we will ensure that the appropriate contracts and safeguards are in place;
• Third party processors for website and App analytics purposes;
• In order to comply with our legal, regulatory and statutory obligations, sometimes we also need to pass your personal information to third parties, such as courts, law enforcement agencies, our insurers, our auditors, and our professional advisers;
• In order to enforce or apply the EULA or to investigate potential breaches of the same and/or protect the rights, property or safety of us, the Pharmacy or our respective customers;
• In connection with a potential sale or transfer of part or all of our business. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Data security

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access and use the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

We will retain a record of your personal data in accordance with relevant law and the following criteria:

• Where we have a reasonable business need to do so, for example, in order to manage our relationship with you;
• Where we are providing products and/or services to you and then for as long as someone could bring a claim against us in respect of those products or services; and/or
• In line with any legal and regulatory requirements or guidance in respect of retention periods.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

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

You have a number of important legal rights regarding the manner in which the personal data relating to you is used.

We have outlined below the key rights which we believe may be relevant to your use of the App and/or the Services.

If you would like to exercise any of these rights then please contact us using the information in the section headed ‘Important information and who we are’ above. Please note that you may be asked to provide us with reasonable proof of your identity so that we can be sure that we are discussing or providing your personal data with, or to, you (or if someone is making a request on your behalf, we need to check that they have the authority to do so).

Please note that the pharmacy services provided to you by your Pharmacy are delivered subject to their own terms and conditions and their own privacy policy and it is therefore important that you check the relevant terms and policies before you use those services to ensure that you are happy with the same.

• Request access to your personal data (commonly known as 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have 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 the processing of your personal data in the following scenarios:
  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use 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. However, 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. For example, if you choose to withdraw consent in respect of Medicines Data then the Services will no longer function. We will advise you if this is the case at the time you withdraw your consent.