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Privacy Policy

1. Introduction
1.1 From the Fields Australia Pty Ltd (ABN 16 635 358 637) trading as Best & Well (Best & Well, we, us, our), understands that your privacy is of the utmost importance to you.
1.2 We understand that providing your personal information to us is an act of trust and we take our privacy obligations extremely seriously. Unless you provide us your consent to act otherwise, the policy as
stated below, will govern how we handle your personal information and safeguard your privacy.
1.3 We are committed to responsible privacy practices and to complying with the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (Privacy Principles) and Notifiable Data Breaches
scheme contained in the Privacy Act, and where relevant, applicable Australian state and territory health records legislation.
1.4 Where applicable, we will handle personal information relying on the related bodies corporate exemption and the employee records exemption in the Privacy Act and any other applicable exemptions in other
2 What is Personal Information?
2.1 Personal Information as defined in the Privacy Act means information or an opinion about an identified individual or an individual who is reasonably identifiable. Personal information includes sensitive
information, which incorporates an individual’s health information.
3 How your personal information is collected.
3.1 In the products and services we provide you, we may collect and store personal information about you (and your consent to use that information):
(a) when you access our Website, or via other links to the Best + Well website (operated by third parties for us) on your mobile or tablet device (Software). Your personal information
including health information may be collected by us through the Software when you, for example
(i) register for and use a Best & Well account;
(ii) place an order for pharmacy products and services, including fulfilling prescription medicines and repeats with your prescriptions;
(iii) enable medication reminders; or
(iv) request a consultation with a doctor via the Best + Well Website.
(b) when Best & Well or our agents contact you to conduct customer satisfaction and market research surveys;
(c) from our partners and service providers that we may use to provide, administer and operate our Software; and
(d) from our related companies.
3.2 Without your consent, we will not collect or monitor any personal information about you, unless we believe it is necessary for the product and services you require or to best service your needs.
4 What personal information we will collect
4.1 The personal information we collect will depend on what products or services you are accessing on our Software, but may include:
(a) your contact details such as your name, date of birth, address, email address, mobile number and or phone number.
(b) your transactional and payment information (excluding your credit card details) if ordering and paying for products and services using the Software;
(c) details of all products and services purchased by you including details of medicines and prescription medicines, your eScript, your dispensing history, and to provide the functionality of the Software
to you; and
(d) information about your browser, your location, the country you are visiting from, your IP address, which pages you visit and what links you click on when you use our Software.
5 For what purposes do we collect, use and disclose your personal information
5.1 The circumstances in which we collect your personal information, will determine the purposes for which we use and disclose your personal information.
5.2 Where practical we will endeavour to inform you as to why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it, at the time we collect your
personal information.
5.3 We collect and use personal information for the following purposes:
(a) to verify your identity;
(b) to provide you with the functionality of the Software, including the ability to purchase pharmacy products and services including fulfilling prescription medicines and repeats with your scripts and
eScripts, medication reminders, access to health programs, and to provide you with an integrated view of your dispensing history;
(c) to provide a more personalised experience from the Software and to improve our products and services and keep you up to date on such improvements;
(d) to assist and enable Best & Well and other health professionals to provide you with pharmacy products and services (e.g. fulfilling prescription medicines and repeats with your scripts and eScripts
and medication reminders);
(e) to market products and services to you based on your profile or activity;
(f) to administer and manage services, including charging, billing and collecting fees;
(g) to analyse customer demographics, health, prescription, adherence, and purchasing trends so that we can tailor our products and services;
(h) to improve the quality of our Software and social media presence;
(i) to respond to you if you have requested information (including via our Software or via an email or other correspondence you send to us) and to address any issues or complaints that you have regarding
our products and services;
(j) to obtain your feedback (directly or through our service providers), to find out your level of satisfaction with our products and services and for other market research activities; and
(k) to contact you regarding any of the above, including via electronic messaging such as SMS and email, by mail, by phone, by fax or in any other lawful manner.
5.4 We may disclose your personal information to third parties in connection with the purposes described above. This may include sharing your personal information with:
(a) our systems, applications (including our mobile intermediary for the purposes of enabling you to manage your active script list through our Software) and our related companies;
(b) Healthcare professionals or their organisations (such as the pharmacist or doctor), in connection with providing health-related products and services to you (including through our Software);
(c) Third parties who provide verification identity checks to enable us to confirm your identity, or as otherwise required or authorised by law;
(d) Specific Third Parties detailed below in clause 5.5 , to administer and operate our Software;
(e) other partners that may facilitate the registering of customers to our Online Services. We may provide to these partners your personal information (excluding your purchase history and health
information) for reporting and reconciliation purposes; and
(f) other service providers that may provide products and services to us including suppliers, marketing agencies, data analysis specialists, data processing organisations, billing and debt recovery
providers, website and data hosting providers and other IT suppliers.
5.5 We may collect from, and disclose personal information to eRx Script Exchange Pty Ltd and other third parties so they can:
(a) To facilitate the provision of pharmacy products and services to you, including but not limited to fulfilling prescription medicines and repeats with your scripts and eScripts, medication reminders,
access to health programs, processing payments for your orders, and to provide you with the functionality of our Software and our booking system;
(b) collect, store and provide to us, your personal information including sensitive and health information;
(c) analyse customer demographics, health, prescription, adherence, and purchasing trends; and
(d) provide targeted marketing of products and services based on your profile or activity.
5.6 The information collected and stored by Third Parties may be disclosed back to us if you obtain any products and services from those parties.
5.7 We will take reasonable steps to ensure that Best & Well, Third Parties, our partners, and other service providers only use your personal information as reasonably required for the purpose we disclosed it to
them and in a manner consistent with the Privacy Act and Privacy Principles and where commercially practical include suitable privacy and confidentiality clauses in our agreement with them.
5.8 We endeavour to obtain your consent to this Privacy Policy at the time you acquire products and services from us, including when you download and use our Software (including when you set up your account). We
will not otherwise disclose your personal information (including sensitive health information) to other companies for a secondary purpose without your express consent.
5.9 If you post information to public parts of our websites, you acknowledge that such information (including your personal information) may be available to be viewed by the public. You should use discretion in
deciding what information you upload to such sites.
6 What happens if you do not agree to provide Personal Information?
6.1 If you do not provide us with certain information about yourself, we may be unable to provide a product or service or the Software to you. Please let us know if you have any concerns about providing personal
information so that we can explain why we are collecting it and tell you about our privacy policy and information management practices.
7 Disclosure of Information overseas
7.1 Some of the third parties to whom we disclose personal information may be located outside Australia. For example, we may disclose personal information to our related companies overseas and to our overseas
service providers.
7.2 Except in some cases where we may rely on an exception under the Privacy Act or other law, we will take reasonable steps to ensure that such overseas recipients do not breach the Privacy Act and Australian
Privacy Principles in relation to such information.
8 How do we protect Personal Information?
8.1 Best & Well will take reasonable steps to keep any personal information we hold about you secure. Please notify us immediately if you become aware of any breach of security.
8.2 Our Software is a secure and in a controlled environment.
9 Accuracy of the Personal Information we hold
9.1 We try to maintain your personal information as accurately as reasonably possible. We rely on the accuracy of personal information as provided to us both directly (from you) and indirectly.
9.2 You can amend the personal information you have provided through our website, or by contacting us on 1300 926 540 or via;
9.3 You may also contact us:
(a) if the personal information we hold about you is incorrect;
(b) to notify us of a change in your personal information; or
(c) to request that we delete or de-identify your personal information.
10 Links, cookies and use of Best & Well websites and applications
10.1 When you visit our website without an account, we may record anonymous information which tells us about visitors to our website but not the identity of those visitors.
10.2 Our websites may contain links to other sites. This Privacy Policy applies to our websites and not any linked sites which are not operated or controlled by us. We encourage you to read the privacy policy of
each website that collects your personal information.
10.3 We use cookies and similar technology on our websites and in other technology applications. The use of such technologies is an industry standard and helps us monitor the effectiveness of our advertising and
how visitors use our websites/applications. We use such technologies to generate statistics, measure your activity, improve the usefulness of our websites/applications and to enhance the ‘customer’
10.4 If you prefer not to receive cookies you can adjust your Internet browser to refuse cookies or to warn you when cookies are being used. However, our websites may not function properly or optimally if cookies
have been turned off.
10.5 When you visit our website, or other digital presences, we may track anonymous information which tells us about your online behaviour, but not your identity.
11 Accessing and correcting your Personal Information
11.1 You may seek access to personal information which we hold about you by contacting us. We will provide access to that information in accordance with the Privacy Act and relevant health records legislation,
subject to certain exemptions which may apply. We may require that the person requesting access provide suitable identification and where permitted by law we may charge an administration fee for granting
access to your personal information.
11.2 If you become aware that any personal information we hold about you is incorrect or if you wish to update your information, please follow the process in section 9 or contact us (see section 13 of this Privacy
12 Queries, comments or complaints about our handling of Personal Information
12.1 If you have any questions, comments or complaints about our collection, use or disclosure of personal information, or if you believe that we have not complied with this Privacy Policy, the Privacy Act or
applicable health records legislation, please contact us.
12.2 When contacting us please provide as much detail as possible in relation to your question, comment or complaint.
12.3 Best & Well will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you
cooperate with us during this process and provide us with any relevant information that we may need.
12.4 If you are not satisfied with the outcome of our assessment of your complaint, you may wish to contact the Office of the Australian Information Commissioner or other relevant regulators.
13 How can you contact us?
13.1 Please address all privacy complaints and requests to update or access information to