INTRODUCTION

At Healthcare Pharmacy we know that your personal information is important, that is why we process it with care and only use the information we need. We do everything we can to ensure that your information is appropriately protected.

This Privacy Policy explains the information we collect from you, how we may use it, and the steps we take to ensure that your information is kept secure. The policy also explains your rights and how to contact us for further information.

What is Personal Data?

Personal data is any information relating to a person who can be either directly or indirectly identified from that information and may include (but is not restricted to) name, address, email address and phone number.

What personal information do we collect?

We collect, store and use (also called processing) personal data in order to provide our patients with the service(s) required.

If you are a patient who receives care, we will have the following information about you:

· Basic details about you: first name and last name, date of birth, next of kin

· Phone number, e-mail address, physical address, and postal code

· Records of medicines you have been prescribed by your doctor or another qualified prescriber, and which have been supplied by this pharmacy

· Details of medicines purchased from the pharmacy without a prescription (over the counter medicines)

· Other details and notes about your health and medical treatment

· Information relevant to your continued care from other people who care for you and know you well, such as other health professionals and relatives; and

· Any other services we provide to you, for example, Medication Therapy Management.

How is the personal information that we collect used?

All the personal information we collect about you and/or any other person whose details you provide will be recorded, processed, and protected in accordance with current data protection legislation. Your data will be kept confidential, used lawfully, fairly and with transparency. Your data will be kept secure and retained for as long as necessary. Primarily we will use your personal information in the following ways: · To fulfil your prescription – we capture your name, address, date of birth, e-mail address, insurance policy number and the medication required (this includes the name of the medication and the dosage instructions) as detailed on the prescription. Capturing this information is necessary to provide you with our service. · We will use your health and medication information provided to dispense and deliver to you your prescriptions or provide other healthcare products and services you have requested. Your prescription information will not be used for marketing. · When we process your personal information for our Legitimate Interests, we make sure we consider and balance any potential impacts on you (both positive and negative), and your rights under data protection laws. We ensure that our legitimate business interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law) · If you enter one of our premises, we may capture you on CCTV. We use CCTV to ensure the safety and security of our staff and customers. The images captured may be used to prevent and detect crime, and therefore, may be shared with law enforcement. We carry out this processing activity either for our own legitimate interest or for the wider public interest (e.g. where it is shared with law enforcement). · We may also provide your telephone number and address to third party delivery services. Where we do so, we ensure the third party only uses the information for this specific purpose and processes it in accordance with an established legal contract. · If you interact with us online (for example, when you use our website, digital services, or post comments on our Facebook page) we will indirectly collect information about you. We collect certain usage information when you utilize our website such as Internet Protocol (“IP”) addresses, log files, unique device identifiers, pages viewed, browser type, any links you click on to leave or interact with our website and the products and services we offer, and other usage information collected from cookies and other tracking technologies. For more information on our Cookie Policy please go to https://healthcarepharmacy.ky/privacy-policy/ · If you fall ill in our premises, we will share your personal information, if we have it, with medical professionals to allow them to deliver appropriate treatment to you. · We do not store your card details when we process your payment card to provide the services you have requested.

Who do we share your personal information with?

There are third parties that we use to deliver services to you. In this section, we have summarized the categories of third parties who we may share your data with. · Postal services and couriers – for typical business purposes, to deliver prescriptions by post and airplane. · Third party Insurance processors – for payment. We may use and disclose your personal information so that we and other covered entities or health care providers can bill and collect payment from you, your insurance company, or a third party. This may include conducting insurance eligibility checks with health plans, determining enrollment status, and providing information to entities that help us submit bills and collect amounts owed. · Law Enforcement Agencies (LEA) – where we are required to do so by law, we will release personal data to LEA’s (e.g. the police). This will most likely be for the detection or prevention of crime, or to exercise or defend a legal claim. · To Individuals Involved in your care or payment for your care. We may disclose your personal information to a family member, other relative, friend, or other individual identified by you, who is involved in your medical care or payment for your care, provided you agree to this disclosure, you had an opportunity to object and did not do so, or we infer from the circumstances in our professional judgment that the disclosure is appropriate. · As Required by Law. We will disclose your personal information when required to do so by local law enforcement in response to a court or administrative order. · To Avert a Serious Threat to Health or Safety. We may use or disclose your personal information when necessary to prevent or lessen a serious threat to any person or the public.

What are your privacy rights and how can you exercise them?

Under law, you have the following rights:

· Right of Access: You have the right to know how we process your personal information (as explained in this notice) and a right to receive a copy of your personal information.

· Right of Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.

· Right to Object: You have the right to object, in certain circumstances, to us processing your personal information.

· Right to Erasure: In certain circumstances, you can ask us to delete your personal information. For example, where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.

· Right of Portability: You have the right to ask us to send a copy of certain elements of your personal information (predominantly information you have shared directly with us) to another company.

· Right to complain: You have the right to complain to the Ombudsman about any perceived violation of the DPA.

To exercise the Right of Access, email us at [email protected] or by letter to:

Data Protection Officer

Healthcare Pharmacy PO Box 453, KY1-1006 Grand Cayman

Cayman Islands Exercising your rights is free and we will respond to any request as quickly as we can. Under current law, we have up to a calendar month (30 days) to respond to any request. We will endeavor to meet this. If we can’t, we’ll contact you to explain why and confirm when your request will be processed.

How long will we keep your personal information?

We will retain your personal information for as long as we are legally or contractually required to do so, or for a period which is justifiable to meet our business needs. The exact retention period varies depending on the type of information and purpose for use, if you require any further information on retention periods please contact us at [email protected]

Security

We take the security of personal information very seriously. We employ security technology, including firewalls, and Secure Socket Layers to safeguard information and have procedures in place to ensure that our paper and computer systems and databases are protected against unauthorized disclosure, use, loss, and damage.

How can you contact us?

At Healthcare Pharmacy Limited the Data Protection Officer is Marla Barnes-Small. Her contact details are: · [email protected] Tel: 345-947-8922 PO BOX 453, KY1-1106 Grand Cayman If you have any queries or concerns about the way Healthcare Pharmacy obtains or uses information about you, please feel free to contact us.

What if you need to complain about how we have used your personal information?

You can make a complaint about how we have used your personal information to us by contacting our Data Protection Officer (using the details above). You are also entitled to complain to the Office of the Ombudsman: https://ombudsman.ky/get-in-touch.

Updating this notice

Healthcare Pharmacy Ltd keeps its privacy policy under regular review and we may make changes to this notice at any time and will either contact you with the modified terms or by posting a copy of them on our website. Any changes will take effect seven (7) days after the date of our email or the date on which we post the modified terms to the website, whichever is the earlier. Your continued use of our services after that period expires means that you agree to be bound by the modified policy. This privacy policy was last updated on 08/02/2021