Fluid Intelligence Privacy Policy
Effective as of 1 March 2023
This policy (‘Privacy Policy’) explains how Fluid Intelligence Pty Ltd (‘FI’ or ‘us’) seeks to protect the Personal Information of individuals.
FI is committed to protecting the safety and security of the Personal Information of individuals whose information FI has access to, including members and users of the FI Platform (defined below) and other persons with whom FI interacts (each a ‘User’ or ‘you’).
The Privacy Policy has been developed in accordance with the Privacy Act 1988 (Cth)(‘Act’). Under the Act, “Personal Information” is defined as:
“Information or an opinion about an identified individual, or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.”
Please read this Privacy Policy carefully in order to understand how your Personal Information is collected, held, used, or otherwise processed by us.
FI reserves the right to make changes or updates to this Privacy Policy from time to time. If this happens we will update this Privacy Policy and notify you of any changes, most likely via email or in-app notification. However, you should also periodically check this Privacy Policy for any updates.
1. ABOUT Fluid Intelligence
FI is a distribution provider that operates a website, mobile applications, an online platform and related services that connect members with pharmacies to ensure the convenient and dependable delivery of a range of goods to members, including without limitation therapeutic goods pursuant to medical scripts (collectively ‘FI Platform’).
In providing the FI Platform, we are sensitive to Users’ concerns about the safety of their Personal Information.
In essence, FI will typically only:
collect, use or share your Personal Information with your consent (unless it is not reasonable in the circumstances to obtain your consent andit is legally permissible for us to do so) or when required by a legal obligation; and
interact with your Personal Information in order to (a) provide you with the FI Platform and information regarding associated goods and services; and (b) help us improve and develop the FI Platform and our service offering generally.
FI has developed our privacy framework to assist Users, and to comply with privacy legislation and regulations applicable to us and our management of your Personal Information.
2. HOW Fluid Intelligence COLLECTS YOUR PERSONAL INFORMATION
FI collects Personal Information from individuals in one of three main ways:
(a) Directly from Users, when they interact with FI or the FI platform (e.g. provide feedback or register a User account);
(b) Passively from Users, when they interact with and use the FI Platform;
(c) From third-parties in certain, specific circumstances (e.g. if you sign up to the FI Platform through a third-party service or platform they may provide us with information you have consented to them sharing).
The types of Personal Information collected in each situation are discussed further below.
3. WHEN Fluid Intelligence COLLECTS INFORMATION FROM USERS AND WHAT WE COLLECT
(a) Personal Information collected directly
When Users sign up to components of the FI Platform we collect the following types of Personal Information directly and consensually:
Basic User information, including your name, email and date of birth, and your gender;
Basic account information, including any display picture or other information you choose to associate with your account;
If you access the FI Platform throughathird-party service or platform(e.g. Facebook), we will collect information that is made available to FI bythose services or platforms. You can generally control the information we receive from these sources by using the privacy settings on the third-party services or platforms.
We will collect the following types of information from Users as they use the FI Platform:
Basic account preferences, such as your settings (e.g. whether you use Touch ID or our repeats feature);
Content that you post and submit to the FI Platform and oursocial media pages, which includes any content from third-party platforms (e.g. a profile picture you may use).
If a User decides to make a purchase over the FI Platform we will collect the following types of Personal Information directly and consensually from you:
Purchase delivery information, such as your preferred delivery date and time, your full address and contact number;
Information about transactions, such as records of your purchases, deliveries and any preferences relevant to the online store component of the FI Platform; and
Payment related information that is required to support your ability to make purchases over the FI Platform (e.g. PayPal account information).
If a User decides to purchase a product that is subject to governmental health benefit schemes (e.g. Medicare), we may collect relevant health benefit identifier information directly and consensually from you (e.g. your Medicare card number and expiry date).
If a User decides to purchase a product that requires a valid doctor’s script (‘Pharmacy Product’), will additionally collect the following types of Personal Information related to the purchase directly and consensually from you:
Script Information, such details contained in the relevant script, a scan of the relevant script, and the hardcopy original of the script; and
Identity Confirmation Information, such as a photograph or scan of valid photo ID (e.g. your Driver Licence), or other associated information contained on it;
(NB– In the case that you are lawfully making a purchase for a minor these types of Personal Information will relate to the minor, and not yourself.)
When a User make an enquiry or sends us unsolicited feedback we may collect the following types of Personal Information directly and consensually:
Basic contact information, including your name and email; and
Feedback information and the details of your interactions with us, including communications with customer support or other FI personnel (e.g. the contents of an in-app “contact us” message, or an email sent to support@Fluid Intelligence.com.au) or other information provided by you regarding your enquiry.
When you respond to a survey we may directly and consensually collect the Personal Information disclaimed on the survey form.
When you make an application for employment at FI, we may collect any Personal Information provided within that application, such as the contents of a personal statement made in support of your application.
(b) Personal Information collected passively
As you interact with the FI Platform or advertisements, we may collect the following types of Personal Information about your usage:
Content that you post in-app, including search terms;
Background account information, such as your notification settings; and
The following types of browser, system and device information regarding devices you link to the FI Platform or use to access our digital content:
Locational information, regarding which country you’re accessing the platform from, (e.g. the form of the IP address from which you access the FI Platform);
Web data tracking information, such asdata from cookies stored on your device, including cookie IDs and settings, as well as logs of your access of the FI Platform;
Device information provided by devices you use to access your FI Platform accounts (e.g. device information from a smartphone); and
System usage information, such as logs of your searches and navigation across the FI Platform.
(c) Personal Information collected from third-parties
In certain specific situations, FI may collect Personal Information about you from third-parties. The types of Personal Information that may be collected include:
Third-party account information made available to us if you register with FI through a third-party service or platform; and
Web data tracking information provided to us that fits certain parameters of who we think could become FI Users (e.g. information about the interests of individuals in the demographic of FI Users). Ordinarily the web data tracking information we may collect or receive from third parties will be pseudonymised (as outlined below).
4. WHY Fluid Intelligence COLLECTS YOUR PERSONAL INFORMATION AND WHAT WE USE IT FOR
Although FI collects Personal Information from Users in a number of circumstances, FI will use or disclose this information as described in this section in order to provide and develop the FI Platform, and consistently with this policy.
Communicating with Users.
FI will use basic User, account and contact information to communicate with individuals about their feedback or issues with the FI Platform.
If Users have consented, FI will also use these types of Personal Information to share relevant news and updates about FI and the FI Platform.
Administration and delivery of FI Platform and products.
FI will use basic User and account information, as well as other basic preferences to provide you with the baseline experience over the FI Platform (e.g. allowing you to access and browse the FI platform).
If you have registered using a third-party service or platform information FI will also use this for the same reasons.
FI will use your basic User informationfor simple administrative tasks, such as resetting account passwords.
FI will use your payment related information to facilitate your access to the online store and purchase of products.
FI will use your health benefit identifier information to organise the purchase of relevant products from pharmacies. In the case of Pharmacy Products, FI will also use your script information and identity confirmation information for this purpose.
FI will use your basic User and purchase delivery information to facilitate delivery of your products. In the case of Pharmacy Products, FI will also use your script information and identity confirmation information for this purpose.
FI will use your account preferences and information about transactions to provide you with a tailored experience when using the FI Platform.
FI will use your Personal Information and information about transactions undertaken by you for the purpose of calculating fees payable or receivable by FI to third parties or to improve the platform, products, and services provided by FI and those third parties.
Ensuring User safety
FI will also use any type of information collected to prevent and address risks to all Users (e.g. FI will use information to investigate suspicious or threatening activity).
Research and development
FI will use the following types of information to develop, test and improve the FI Platform:
Survey and feedback information, as well as any content that is submitted in relation to products or features of the FI Platform;
Basic account and online store preferences;
Content you submit, either directly through the FI Platform or through third-party platforms or services.
Background account, browser, system and device information; and
Third-party web tracking information.
Together these types of Personal Information are used to provide us with an overview of how the FI Platform is being used, any shortcomings it may have, and subsequently to highlight what will be the best means of improving the experience for all Users.
FI's preference will be to de-identify these types information first, and then use it for this purpose in conjunction with de-identified browser and device information (see section 6 below for an explanation of what we mean by “de-identified”).
Marketing
Where Users have consented, FI or our third-party service providers will use basic contact, enquiry, account, third-party account and web data tracking information to provide Users with relevant marketing materials and offers about FI and the FI platform. Users can always opt out of this through the functionality provided in each marketing communication (e.g. by clicking “unsubscribe” at the bottom of an email).
In some instances, where Users have expressly consented, we will also use these types of information to provide Users with personalised health intervention content and messages.
We use some basic information collected from our platform to enable us to display advertisements for Fluid Intelligence that may be of interest to you on other websites via third parties (such as Google, YouTube, Facebook).
Any data matched with these platforms is used strictly in relation to Fluid Intelligence activity and will not be used for any other marketing or advertising of third party services. We do not share any health related data with these platforms.
For more information and the ability to control your preferences on these platforms, visit:
https://adssettings.google.com/authenticated
https://policies.google.com/privacy/partners
https://www.facebook.com/ads/preferences/
5. Fluid Intelligence’S DISCLOSURE OF PERSONAL INFORMATION
Generally, FI does not disclose Personal Information to any third-parties except:
Pharmacies and service providers (e.g. delivery personnel and Payment Card Industry Data Security Standard (‘PCI DSS’) compliant third-party payment operators) FI engages to help us provide and develop the FI Platformand process the Personal Information we collect; and
Law enforcement agencies, or another party that has a legitimate legal right to access the information.
third-party-service providers that have referred a User to the FI Platform, in which case the Personal Information of that User (or de-identified information relating to that User) may be shared with that third-party
The above disclosures will only be made in circumstances where the recipient has provided an undertaking that they will maintain the confidentiality of the information and that they recognise the appropriate limitations placed on the use of the information. Disclosures will also always be in accordance with this Privacy Policy.
Overseas Disclosure
Some of the third-parties FI discloses Personal Information to are located overseas. This is particularly the case for our third-party software and cloud service providers which are currently located in the United States.
As with disclosures to third-party service providers, overseas disclosures are always made once FI has taken all reasonable steps to determine the information will be treated at least as favourably under the Act and other applicable privacy laws.
6. Fluid Intelligence’S TREATMENT AND STORAGE OF INFORMATION
FI's general approach
FI will keep your Personal Information confidential and not sell or knowingly divulge User information to any external third-parties, unless:
We believe, in good faith, that we are required to share the Personal Information with a third party in order to comply with legitimate legal obligations;
The disclosure is to a third-party processor of Personal Information that acts on our behalf and/or under our instruction in order to enable us to develop and deliver the FI Platform (e.g. a cloud service provider or local marketing and development partner);
Other entities acquire ownership or operation of FI or the FI Platform; and/or
We need to protect the safety of Users, and the security of our FI Platform.
FI seeks the informed and voluntary consent of individuals whenever it collects their Personal Information, or as soon as possible after.
Users can always refuse or revoke this consent, but sometimes this will affect FI's ability to provide them with the FI Platform and other offerings. FI will advise Users if this is the case.
De-identification
De-identified information refers to information that cannot reasonably be used to identify a particular individual.
De-identified information that will neverbe able to personally identify particular individuals is referred to as anonymised information (e.g. statistics that show 90% of Users were happy with the FI Platform). Additionally, de-identified information that can identify individuals only if it is combined with another, separate piece of information is referred to as pseudonymised information (e.g. account ID numbers).
Where possible FI will aim to collect, store and use anonymised information as a first preference, and if not, then pseudonymised information.
However, sometimes it will be impractical for User information to be de-identified or treated in this way, and in this case, FI will continue to use and hold the information in a personally identifiable state. For example, if FI needs to reply to a User enquiry we will have to use the contact information provided.
Security
FI is committed to information security. We will use all reasonable endeavours to keep the Personal Information we collect, hold and use in a secure environment. To this end we have implemented technical, organisational and physical security measures that are designed to protect Personal Information, and to respond appropriately if it is ever breached (e.g. FI has developed an extensive Data Breach Response Plan which we use to prepare and respond to data breaches).
When information collected or used by FI is stored on third-party service providers (e.g. Azure or AWS cloud servers), FI takes reasonable steps to ensure these third-parties use industry standard security measures that meet the level of information security FI owes Users.
As part of our privacy framework we endeavour to routinely review these security procedures and consider the appropriateness of new technologies and methods.
Data Breaches
In the circumstances where FI suffers a data breach that contains Personal Information, we will endeavour to take all necessary steps to comply with the Notifiable Data Breach Scheme outlined under the Act.
7. Fluid Intelligence’S RETENTION OF INFORMATION
FI retains Personal Information until it is no longer needed to provide or develop the FI Platform, or until the individual who the Personal Information concerns asks us to delete it, whichever comes first. It may take up to 30 days to delete Personal Information from our systems following a valid request for deletion.
However, FI will retain:
Personal Informationin circumstances where we have legal and regulatory obligations to do so (e.g. for law enforcement purposes, employment law, corporate or tax record keeping, or where the information is relevant to legitimate legal proceedings); and
anonymised information for analytic and service development purposes.
The information we retain will be handled in accordance with this PrivacyPolicy.
8. MANAGING YOUR PERSONAL INFORMATION
Accessing and ensuring the accuracy of Personal Information
FI takes reasonable steps to ensure that the Personal Information we collect and hold is accurate, up to date and complete.
Users have a right to access and request the correction of any of their Personal Information we hold about them at any time. Any such requests should be made by directly contacting us at the details set out below. FI will grant access to the extent required or authorised by the Act and applicable laws, and will take all reasonable steps to correct the relevant Personal Information where appropriate.
There may be circumstances in which FI cannot provide Users with access to information. We will advise you of these reasons if this is the case.
Contacting FI
FI has appointed a Privacy Officer to be the first point of contact for all privacy related matters and to assist in ensuring our compliance with our privacy obligations.
Privacy Officer
Privacy Officer
Email: privacy@fluidintelligence.com.au
Gateway Building Level 36, 1 Macquarie Place Circular Quay NSW 2000
If you have any queries or wish to make a complaint about a breach of this Privacy Policy or the Act you can contact or lodge a complaint to our Privacy Officer using the contact details above. You will need to provide sufficient details regarding your complaint as well as any supporting evidence and/or information.
The Privacy Offer will respond to your query or complaint as quickly as possible. FI will contact you if we require any additional information from you and will notify you in writing (which includes electronic communication via email) of the relevant determination. If you are not satisfied with the determination you can contact us to discuss your concerns or complain to the Australian Privacy Commissioner via www.oaic.gov.au.
This Privacy Policy was last updated on March 26th 2023.