Privacy statement

Last version: 09 February 2022

 

Of course, safeguarding your privacy is very important to us. We understand that the success of our services depends on the trust you have in how we handle your personal data.

In this privacy statement, we explain how we do this, what data of yours we process and why. This allows you to make a good decision about whether you want to use the app and gives you control over your data. We therefore recommend that you read this privacy statement carefully.

This privacy statement applies to all activities that take place in this App.

 

Provider of this App (data controller)

The mobile Pharmacy forYou application (hereinafter the "App") offers various care-related services, all on behalf of your pharmacy. Do you have questions about the App or the data it processes? Please contact your pharmacy. You can find your pharmacy's contact information in the App under Profile, or at 'View participating pharmacies' if you are not logged in.

 

Supplier of this App: SmartMed (processor)

SmartMed Pharmacy B.V. (hereinafter "SmartMed") is the provider of this App. This App is provided by SmartMed on behalf of your pharmacy. The privacy policy of your pharmacy continues to apply. This statement only describes, in addition to the privacy policy of your pharmacy, what happens when you use the App. If you have any questions about privacy, please contact your pharmacy.

SmartMed is an IT company that supplies software to pharmacies, among others. If your pharmacy uses our software, and if your pharmacy instructs us to do so, we can show you data from your pharmacy's records via the App.

SmartMed always acts on behalf of the pharmacy. We do not do anything with your data on our own initiative and we will never use the data for our own purposes. It is and remains the pharmacy that determines which data is entered, modified or deleted in the administration.

If you have any questions about the processed data, please refer to your pharmacy. The pharmacy can inform you further about its privacy policy.

 

Why do we process data (legal basis)

If you use the services through this App, privacy-sensitive data (also called: personal data) will be processed. In order to process personal data, there must always be a 'good reason' to do so; this is called the 'legal basis'. In this App, there are two reasons:

  • Legal requirement: The app displays data from your pharmacy patient profile. The reason for processing this data is legal obligation. Your pharmacy is legally obliged to keep this data up to date.
  • Permission: By using the App, you give permission for the data from your pharmacy patient profile to be made available to you via the App. You also give permission to process the data that you enter yourself. For example, your e-mail address to create your account and to send a message to your pharmacy when you make a repeat request.

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What personal data are processed and how do we obtain them?

We distinguish between a number of types of data. Data that you enter yourself, for example when creating an account and linking a pharmacy in the App, entering your own medication or user preferences. And data that we collect from the records of the pharmacy to which you are linked and where you are registered as a patient.

Account and link data (entered by yourself)

An e-mail address, which is also known at your pharmacy

  • A password
  • A PIN code
  • A pharmacy
  • A BSN

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Organisation data (retrieved)

  • The details of your pharmacy, such as location, contact information, opening hours and services

 

Medical data (retrieved and self-entered)

  • Your active medication, as recorded in the records of your pharmacy.
  • Your self-administered medication.

 

Data processing for account creation and linking pharmacies

To use the services in the App, you need an account and a link to a participating pharmacy where you are registered. For your account, SmartMed uses KeyCloak, which provides identity and access management. Your pharmacy must also verify your identity before your medication data can be linked to your account.

The App uses your e-mail address to create an account, and as an additional verification of your identity, by using the same e-mail address that is known and verified by your pharmacy.

After creating an account or logging in, you remain logged in to the app until you log out again. You set yourself a PIN code for fast and secure access to the app. If your device supports it, you can also use your fingerprint or facial recognition instead of a PIN code.

To link your App account to your pharmacy, choose a participating pharmacy where you are registered. Then you enter your BSN. The App checks on behalf of your pharmacy whether you (your BSN) are registered with the chosen pharmacy, whether your account email address is the same as that known to the pharmacy and whether your pharmacy has given patient profile approval for the use of this App.

For security reasons, we deliberately do not use linking with social media accounts.

 

Data available in the App

After connecting with your pharmacy, the App will show certain data from your patient profile in the pharmacy. If, in addition to your linked pharmacy, you are registered at another pharmacy that also uses the SmartMed application, the medication data from that other pharmacy will also be visible in the App.

Data from your linked pharmacy that are visible in the App include:

  • Personal data, such as name, address, place of residence, gender, telephone number
  • Pharmacy data, such as name, location, contact details, opening hours, services
  • Medical data, such as your active medication and (repeat) orders

 

Data processing for repeat requests

In this App you can make a repeat request for active medication that may be repeated via the App. When you make a repeat request for medication, a secure message is sent to your pharmacy (the pharmacy that provided this medication). Your repeat request will enter the system of your pharmacy. You will be informed about the status of your repeat request by your pharmacy, in the same way as for repeat requests made via another route. For example by telephone or at the counter.

 

Adding data processing to medication

If you add medication yourself, the app will store this information in your patient file. Your pharmacy will not be notified that you have added medication and will therefore not take any proactive action. The pharmacy has no direct access to the medication you added yourself, but can request this information.

 

Data processing for reminders

Under Reminders you can indicate whether you have taken or skipped your scheduled medication. At the moment, this information is only stored locally on your device (encrypted). Your pharmacy is not yet able to see what you enter.

 

Data processing in search pharmacies

If you give us permission, we will use your location to show your location on the map when you search for a pharmacy. If you choose 'directions', your location will be passed on to the navigation app you choose so that your route to your pharmacy can be calculated. Your location will not be used at other times. You can always turn your permission for this on or off in the settings of your device.

 

What data do we store and how long do we keep your data?

In the first place it is your pharmacy that determines how long your data is kept. If your pharmacy deletes data from its records, we no longer have that data either. SmartMed has no role in this.

When using the App, some data is stored locally on the device. We store this data locally so that you can work with the App even when you are not connected to the Internet.

The data we store locally are encrypted:

  • Personal data;
  • Medical records;
  • User settings;
  • Pharmacy;  
  • Personal ID in the pharmacy;
  • PIN code;
  • Use Touch-ID / Face-ID.

The retention period of the data stored on the device is directly dependent on the duration of use of the App. If you no longer wish to use the services of this App, you can delete it from your device in the usual way. While deleting, all locally stored data will also be deleted from your device.

 

Safety measures

SmartMed has an internal quality system with which we continually assess and improve our organisation and internal processes. SmartMed is ISO27001 and NEN7510 certified and works in accordance with all major guidelines of information security in healthcare.

Locally stored data is encrypted and can only be accessed from the App with the correct key. Others cannot view this data.

All communications are encrypted via HTTPS. Our network servers are located in secure data centres within the European Economic Area (EEA) and are monitored.

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Your rights

The General Data Protection Regulation (AVG) gives you a number of privacy rights. These are listed below.

  • Right of accessYou have the right to inspect the personal data that have been processed about you. There are some legal exceptions to this.
  • Right of rectificationAre your details incorrect, incomplete or irrelevant? Then you can ask your pharmacy to amend or supplement your data.
  • Right to erasureYou have the right to have your data deleted by your pharmacy in a number of cases. You can delete the data related only to your App account yourself by deleting your account.
  • Right to restrict processing: In a number of cases, you have the right to have your pharmacy still retain your data, but no longer process it at your request. This is the right to restrict processing.
  • Right to data portabilityYou can invoke the right to data portability if this App processes your data because you have given your consent.
  • Right to object: You may object to the use of your personal data by your pharmacy.
  • Right to withdraw consent: If you have given your pharmacy or this App permission to process certain data, you have the right to withdraw that permission.

Do you wish to exercise any of the rights mentioned above? Please contact your pharmacy.

 

Changes

It is possible that new versions of the App will change this privacy statement. Should this be the case, this will be communicated the first time you use the App.

 

Questions? Comments or remarks? Any complaints?

For questions regarding the processing of your personal data, please contact your pharmacy. If you have specific questions about what happens when using the App, please contact our DataProtection Officer:

E-mail:security@smartmed.world