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Privacy Policy  


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Last updated: 22nd May 2018

Consumers and patients - Web-based Prescription Order Form

Refill Assistant operates the web-based Prescription Order Form provided to Coens Pharmacy. The form is typically embedded in a page on the pharmacy’s own website.


This Privacy Policy explains how Refill Assistant handles the personal information of consumers and patients, specifically consumers and patients of Coens Pharmacy that use the Coens Pharmacy web-based Prescription Order Form.


In this regard, Refill Assistant’s core activities and functions include the following:

  • a service provider for community pharmacies – Refill Assistant provides and manages a software platform, known as the Pharmacy Portal, for Coens Pharmacy which enables Coens Pharmacy to process prescription and dispensing information and to deliver professional services to patients and consumers;
  • a provider of the Coens Pharmacys own secure web-based Prescription Order Form.


In this Policy, “you” and “your” refers to consumers and patients of Coens Pharmacy that use the web-based Prescription Order Form. Where appropriate, you and your also refers to caregivers of consumers, patients and users.


1. Collecting your Personal Information


1.1 How we collect personal information


We collect your personal information directly from you when you:


  • enter personal information into the web-based Prescription Order Form and Submit this form to the pharmacy,


1.2 Types of personal information we collect


The personal information that we collect may include:


  • your identity and contact details including name, address, email address, phone number and date of birth;



1.3 Collecting health and other sensitive information


We collect the following health or other sensitive information about you:


  • medication, prescription and dispensing information, including historical information;
  • messages between you and Coens Pharmacy related to a specific prescription or dispensing


By providing your health information to us and Coens Pharmacy, you consent to us collecting your health information and using and disclosing it for the purposes set out in this Privacy Policy.


1.4 Our Legitimate Interests: Why we collect personal information


We collect your personal information so that we can provide you and Coens Pharmacy with our services, including the functionality and maintenance of our software platform and any products that you or Coens Pharmacy may have requested. We collect your personal information to carry out our functions and activities, such as providing pharmacies the means to process prescription orders on your behalf and to contact you.


The purposes for which we collect your personal information may include to:


  • allow pharmacy staff to verify your identity;
  • provide Coens Pharmacy with an IT service via our software platform;
  • provide the services and functionality of the web-based Prescription Order Form to you;
  • allow the Coens Pharmacy to process your medication Order or Query; and
  • help us to continuously improve the services and products we offer.


1.5 Specific Uses of the Information we collect


User entered information

  • Patient Information
    • Full Name - Used by the pharmacy for identifying a patient.
    • Date of Birth - Used by the pharmacy for identifying a patient.
    • Address - Used by a pharmacy for identifying a patient and may be used for delivery of medications if required.
    • Phone - May be used by a pharmacist to contact a patient during the course of processing an order to get clarifications or other extra information.
    • Email address - The Pharmacist can use this to communicate with a patient regarding a specific medication or order via email.


  • Order Information
    • Medication Name - Can be used by the pharmacist to identify the correct medication to be dispensed.
    • Photo of prescription or already ordered medication - Can be used by the pharmacist to identify the correct medication to be dispensed.
    • Notes, Comments & Additional Information - Can be used to specify more details about the medication requested and any other information useful for dispensing the required products.


Automatically collected information

  • Patient
    • Information about a user’s web browser - name and version of web browser may be used for troubleshooting, IP Address can also be used for troubleshooting specific issues.


EU Members’ Rights
You have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below:

Access and Porting
You can access all of your information by asking your pharmacy to provide this to you. Please contact your pharmacy to request assistance, the pharmacy will need to verify your identity satisfactorily before complying with the request.

Rectify and Delete
You can have your data deleted by requesting your pharmacy to do so. Please contact your pharmacy to request assistance, the pharmacy will need to verify your identity satisfactorily before complying with the request.


Restrict Processing

You have the right to restrict processing of your personal data. Please contact your pharmacy to request assistance, the pharmacy will need to verify your identity satisfactorily before complying with the request.

Where we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

Revoke consent
Where you have previously provided your consent, such as to permit us to process health-related data about you, you have the right to withdraw your consent to the processing of your information at any time. You can withdraw your consent by requesting your pharmacy to restrict processing or delete information. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.

If you have a complaint about how we have handled your personal information, you can contact us using the details below:


Refill Assistant,

Unit 6, Village Green,

Church Road,





Once we have received your complaint, we will investigate and respond to you within a reasonable period of time. Our aim is to resolve any complaint within 10 working days of receiving the complaint. If this is not possible, we will contact you and let you know why and how long we think it will take.


We take any privacy complaint seriously and will deal with your complaint fairly and promptly. However if you are not satisfied with our response or how we handled your complaint, you may make a complaint to your local supervisory authority. 

You can find the contact details of your national supervisory authority below:



Retention of Information

We retain Patient and Order Information submitted through the web-based Prescription Order Form for 1 year. We retain your automatically collected information such as IP Addresses for 7 days.


Age of Consent


Any user of this service under the age of 18 needs to have the consent of a parent or guardian to order prescription medication and to use this app. The pharmacy is required to identify the patient and ensure they meet the age criteria or have the consent of a parent or guardian before providing medication to the user or processing any information provided through the service.



2. Use and disclosure of Personal Information


We will use and disclose your personal information for the purposes described in ‘Our Legitimate Interests: Why we collect your personal information’. If we need to handle your information for any other purpose, we will only do so with your consent or where you may otherwise reasonably expect us to do so.


We may also disclose your personal information to:


  • Any service provider we engage to carry out our business functions and activities (to the extent reasonably necessary to do so) such as:
  • outsourced service providers who manage the services we provide;
  • any entity to which we are required or authorised by or under law to disclose such information (for instance, law enforcement agencies, courts and government bodies);


We take steps to ensure that third party recipients are obliged to protect the privacy and security of your personal information and use it only for the purpose for which it is disclosed.


General information


This section of the Privacy Policy provides you with general information about how Refill Assistant handles the collected personal information.


1. Storage and security of your Personal Information


We store personal information in encrypted electronic form. We use third party service providers to store some personal information. These third party service providers are located in Europe and the U.S. and comply with privacy and security legislation including GDPR and HIPAA.


The security of personal information is important to us and we take reasonable steps to protect it from misuse or loss and from unauthorised access, modification or disclosure. Some of the ways we do this include:


  • imposing security measures for access to our computer systems;
  • For pharmacy personnel, we enforce two-factor authentication using either U2F security tokens or one time codes over SMS
  • All information transferred is only ever transmitted over a secure connection
  • When the personal information we collect is no longer required, we will delete it.
    • For example if a Coens Pharmacy no longer requires the pharmacy app service and cancels their subscription, the pharmacy data and all patient information and medication history is deleted from Refill Assistant systems within 30 days.
    • If Coens Pharmacy requests Refill Assistant to delete an individual patient’s data, this data is removed from the platform within 30 days.


2. Breach Reporting


If a Breach of our systems is discovered we will

  • inform the Data Protection Commissioner within 72 hours of our discovering and confirming the scope of the breach
  • inform the individuals concerned if the breach is likely to bring harm to an individual such as breach of confidentiality



3. Changes to our Privacy Policy


We may update our Privacy Policy from time to time. Our Privacy Policy was last updated in May 2018. By using our web-based Prescription Order Form or otherwise continuing to deal with us, you accept this Privacy Policy.