privacy Policy

We understand the importance of protecting your personal information. This Privacy Policy outlines our commitment to safeguarding the privacy of personal information provided to us or collected by us, offline or online, through our services, website, telehealth introductory platform, and pharmacy introductory platform (Services). In this Privacy Policy, "we," "us," or "our" refers to Refr Health Pty Ltd.

Personal Information

We may collect the following types of personal information about you:

As a patient:

  • Your name

  • Your date of birth

  • Your contact details, including email address, mailing address, street address, and telephone number

  • Your credit card or other payment details (processed through our third-party payment processor)

  • Your sensitive information as detailed below

  • Images of you for your profile

  • Your preferences and/or opinions

  • Your general practitioner’s details

  • Information you provide to us through patient surveys

  • Details of the medications you have requested/received and any other services or support we have provided to you and/or that you have enquired about, and our response to you

  • Details of the consultations you have requested/received and any other services or support we have provided to you and/or that you have enquired about, and our response to you

  • Any other personal information requested by us and/or provided by you or a third party

As a user of our services:

  • Your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries, and/or browsing behavior

  • Information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using, and the domain name of your Internet service provider

  • Additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms, and/or accounts from which you permit us to collect information

  • Any other personal information about your use of the Services requested by us and/or provided by you or a third party

We may collect these types of personal information directly from you or from third parties.

How We Treat Personal Information That Is Also Sensitive Information

Sensitive information is a subset of personal information given a higher level of protection under the Australian Privacy Principles. Sensitive information includes information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information, or biometric information.

The type of sensitive information we may collect about you includes:

As a patient: Your health information such as medication prescriptions, imaging, test results, and clinical letters provided by a doctor.

As a doctor or pharmacist: Information about your criminal history and working with children check.

We will not collect sensitive information about you without your consent unless required or authorised by law.

With your consent, your sensitive information may only be used and disclosed for the primary purpose for which it was collected and for reasonably expected purposes directly related to the primary purpose, such as:

  • Using third parties to directly assist us in providing our Services (e.g., data hosting providers)

  • Allowing doctors or pharmacists to provide their services to you, including holding your telehealth consult or filling your medication order (as applicable)

  • Informing your general practitioner or allied health practitioner of the services provided by a doctor or pharmacist, if required

  • Assessing your application to join our introductory platform, if you are a doctor or pharmacist

  • Referring you to other medical or health service providers in circumstances where it is impractical for us to obtain your consent

Sensitive information may also be used or disclosed if otherwise permitted, required, or authorised by law.

Collection and Use of Personal Information

We may collect, hold, use, and disclose personal information for the following purposes:

  • To enable you to access and use our Services and associated applications

  • For doctors and pharmacists to provide their services to you as a patient, including holding your telehealth consult or filling your medication order (as applicable)

  • To consider your application if you have applied to be a doctor or pharmacist on our introductory platform

  • To contact and communicate with you about our Services

  • For internal record-keeping, administrative, invoicing, and billing purposes

  • For analytics, market research, and business development, including to operate and improve our Services and associated applications

  • To offer additional benefits to you

  • For advertising and marketing, including sending you promotional information about our products and services and information about third parties that we consider may be of interest to you

  • To comply with our legal obligations and resolve any disputes that we may have

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

  • Doctors and pharmacists, as required, to provide their services to you as a patient, including holding your telehealth consult or filling your medication order (as applicable)

  • Third-party service providers to enable them to provide their services to us, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors, and payment systems operators

  • Patients, as required, to allow them to use our Services and benefit from your services if you are a doctor or pharmacist

  • Our employees, contractors, and/or related entities

  • Our existing or potential agents or business partners

  • Sponsors or promoters of any additional benefits we offer

  • Anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred

  • Credit reporting agencies, courts, tribunals, and regulatory authorities in the event you fail to pay for goods or services provided to you

  • Courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or to establish, exercise, or defend our legal rights

  • Third parties to collect and process data, such as data analytics businesses. This may include parties that store data outside of Australia

  • Regulatory bodies, doctors, or allied health professionals if it is unreasonable or impracticable to obtain your consent and we reasonably believe that the disclosure is necessary to lessen or prevent a serious threat to the life, health, or safety of any individual, or to public health or safety

  • Any other third parties as permitted, authorised, or required by law

Disclosure Overseas

We may disclose personal information overseas. The countries to which we send personal information for the purposes listed above may not have the same privacy laws as Australia. If we disclose your personal information to third parties in other countries, we will perform those disclosures in accordance with the requirements of applicable law.

Your Rights and Controlling Your Personal Information

Your choice: Please read this Privacy Policy carefully. By providing personal information to us, you understand that we will collect, hold, use, and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us; however, if you do not, it may affect your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have that person’s consent to provide the personal information to us.

Anonymity: Where practicable, we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

Restrict and unsubscribe: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. You may also unsubscribe from our email database or opt-out of marketing communications by using the opt-out facilities provided in the communication.

Access: You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Complaints: If you wish to make a complaint about how we have handled your personal information, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and aim to respond to you within one month of receipt of your complaint, in writing, setting out the outcome of our investigation and the steps we will take to address your complaint. You also have the right to contact the relevant authority.

Storage and Security: We are dedicated to ensuring the security of the personal information we gather. To prevent unauthorized access or disclosure, we have implemented appropriate physical, electronic, and administrative measures designed to protect personal information from misuse, interference, loss, unauthorized access, modification, and disclosure. As part of our security protocols, we may occasionally ask for proof of identity before disclosing personal information to you. We are unable to ensure the security of any information sent to or received from us through the Internet. Transmitting and exchanging information is done at your own risk. Despite our efforts to protect against unauthorized disclosures, we cannot guarantee that the personal information we collect will not be disclosed in a way that is inconsistent with this privacy policy. If we learn of unauthorized access, disclosure, or loss of your personal information, we will implement our data breach response plan and take all reasonable measures to minimize any risk of serious harm. Where necessary, we will notify you of the data breach in accordance with our legal obligations.

Cookies and Web Beacons: We may use cookies on our online services periodically. Cookies are text files placed in your browser to store your preferences. On their own, cookies do not reveal your email address or other personally identifiable information. However, they enable third parties, such as Google and Facebook, to display our advertisements on your social media and other online platforms as part of our retargeting efforts. If you choose to provide our online services with personal information, this information may be linked to the data stored in the cookie. You can block cookies by adjusting your browser settings to refuse all or some cookies. However, blocking cookies (including essential ones) may prevent you from accessing all or parts of our online services. We may also use web beacons on our online services. Web beacons (also known as clear GIFs) are small pieces of code placed on a web page to monitor visitors’ behavior and gather data about how they view a web page. For example, web beacons can be used to count the number of visitors to a page or to deliver a cookie to the browser of someone viewing that page.

Links to Other Websites: Our services may include links to other websites. We have no control over these external sites and are not responsible for the protection and privacy of any personal information you provide while visiting them. These websites are not covered by this Privacy Policy.

Amendments: We reserve the right to modify this Privacy Policy at any time. Any changes will be published on our website. We encourage you to check our website regularly to stay informed about our current Privacy Policy.