1. INTRODUCTION

1.1 Purpose of the Privacy Notice

At Fontana Pharmacy Limited (Referred to as “Fontana”, “we”, “our” or “us” throughout this notice), we are dedicated and geared towards the safeguarding your personal data and protecting your privacy. This policy sets out how we will treat your personal data, what personal data we collect from you both offline and online through our website and other services. It explains what we use your personal data for and how we protect your personal data and keep it safe. It also addresses the rights and choices you have about your personal data and how you can exercise your rights. By using our services, you are acknowledging the terms of our Privacy Policy and accept our collection, use, disclosure, and retention of your personal information as described in our Privacy Policy.

This notice reflects our general practices with regards to Personal Data and is in accordance with our privacy principles below:

• Be transparent about personal data we collect.
• Use personal data only for specific purposes.
• Limit collection only the minimum necessary personal data.
• Keep your personal data accurate and up to date.
• Only keep your personal data for as long as necessary
• Respect your rights as it relates to your personal data.
• Guard your personal data.

1.2 Scope and Application

This privacy notice is intended for:

i.     Visitors and regular users of the Fontanapharmacy.com website (the “Website”) 
ii.    Customers
iii.   Employees
iv.   Members of our loyalty program
v.    Patients who fulfill their prescriptions with us
vi.   Job applicants who inquire about or apply for a job with us.
vii.  Suppliers, service providers and business partners to whom we have relationships.
viii. Any individual who interacts with us in the course of our business

This notice should be read together with any other privacy statements or supplemental notices available at our locations which may have additional information relevant to your experience.

“Personal Data” as used in this notice means information about an individual that can reasonably be used either alone or with other information to identify the individual. It may also include information about a browser or device used by such an individual”.

In this notice, personal information and health records are collectively referred to as “Personal Data”.

2. WHAT PERSONAL DATA WE COLLECT AND HOW

2.1 Personal data we collect.

Personal data that we collect and process may include:

• Basic Identifiers – Name, Date of Birth, TRN, NIS, driver's license or other state issued identification number, passport number  
• Contact Information – Personal email, mailing/shipping address, billing address, telephone number
• Financial Information – Credit and Debit card information, bank details, account number
• Health Information – Prescriptions histories, allergies, health insurance information, medical records and other information about your health and your prescriptions, that has been collected or generated by your pharmacist for the purpose of managing your prescriptions and prescription refills
• Demographic information: Age, gender, race or ethnicity, ancestry, national origin, citizenship, place of birth, religion or creed, marital status, physical or mental disability.
• Biometric Information – Eye colour, photo ID, height, weight
• Behavioural information - information relating to any transactions carried out between you and us on or in relation to this website, including data relating to any purchases you make of our goods or services
• Technical information – information about your device and your usage of our websites including your IP address, device ID, type of browser, geographical location, browser type, referral source, length of visit and number of page views
• Professional or employment related information: If you apply for a position at Fontana, we will collect the information contained in your resume and cover letter as well as any information you decide to share with us as part of the application process
• Any information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters or loyalty program
• Any other information that you choose to send to us

2.2 How we collect Personal Data

We collect personal data voluntarily provided to us, and we also collect your personal data from third-party sources. The information collected depends on the purpose for which it is being collected. In general, your personal health data is collected directly from you or your authorized representative, or your healthcare provider. When necessary, our pharmacists may need to speak to your physician and other healthcare providers within your circle of care in order to obtain the information they need. 

• Directly from you - We collect personal information that you voluntarily provide to us in our stores, by mail, by email, over the telephone, through our website or in any other direct manner.
• From third party sources - We may receive your personal data from other sources with your consent or if the law requires or permits us to do so. For instance: job boards, social media platforms, third parties that help us with recruitment, and other third parties.

3. LEGAL BASIS FOR PROCESSING

We only collect and use your personal data where you have specifically given us your consent when such consent is obligatory and where we have a legitimate reason for doing so. In which instance, we only collect personal data that is reasonably necessary to provide our services to you.

4. HOW WE USE YOUR DATA

Your personal data will be used for the purposes specified in this privacy notice or for any other purpose reasonably compatible to the purposes provided. In addition to using your personal data to deliver our products and services to you or to provide information you request, we may also use it:

• To fulfill your purchases and process your transactions and returns either through our website or in store
• To provide customer service and support
• To create, administer and manage your account for our loyalty programs including birthday programs, vouchers, reward discounts, gift cards
• For email marketing, telemarketing, and direct mail campaigns. If we intend to share electronic marketing with you, we will ask for your consent where required and you can opt out at any time;
• To manage your records, dispense your medications and provide initial and, where appropriate, on-going counseling with respect to your prescription(s);
• To deliver pharmacy professional services
• To communicate with you to advise you of prescription refills and other health-related information as well as services that may be of assistance or interest to you;
• To provide pharmacy or other health-related capabilities online or through mobile applications;
• To respond to requests made by, or on behalf of, your insurance provider to review your insurance claim(s);
• To obtain and process payments for prescriptions and healthcare services;
• To monitor and investigate incidents and manage claims;
• To verify the accuracy of the contact information that you provide us
• To process job applications and administer the employment relationship
• To manage our workforce effectively;
• To manage our relationship and keep records related to our relationship
• To administer our website, manage your account on our website and improve your browsing experience by personalizing the website.
• To respond to your queries and provide you with information when you request it
• Perform analytics, market research and segmentation to understand your preferences, improve our products and services and our communications to you.
• As may be necessary to: (a) to comply with applicable laws and regulations; (b) to respond to requests from public and government authorities; (c) to inform you about changes to our terms, conditions and policies; (d) to protect our operations against potential, threatened or actual litigation; (e) to investigate and take action against illegal or harmful behaviour; (f) to protect our rights, your vital interests, or those of another person

5. HOW WE SHARE YOUR DATA

We share your personal data on a need-to-know basis and to the extent necessary to comply with applicable laws and regulations. We do not give, rent, or sell personal data to any organization or individual.

We may share your personal data to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes as set out in this privacy notice. Categories of third parties and service providers with whom we share personal data include:

• Employment and recruitment agencies
• Insurance and financial services
• Insurance administrative service providers
• Professional advisors such as Auditors and legal counsels
• Software service providers
• Hosting service providers
• Courier service providers
• Data storage service providers
• Government entities, law enforcement, health authorities
• Financial reporting service providers
• Payroll service providers
• Any entity who may acquire us or part of our business or brands.
• Any person who you direct to contact us such as your authorised representative, our designated caregiver.

In addition, we may share your personal data:

• To the extent that we are required to do so by law.
• In connection with any legal proceedings or prospective legal proceedings.
• In order to establish, exercise or defend our legal rights including providing data to others for the purposes of fraud prevention and reducing credit risk; and
• to the purchaser or prospective purchaser of any business or asset which we are or are contemplating selling.

6. HOW LONG WE KEEP YOUR DATA

We retain your personal data only for as long as we need to. The retention period may depend on the purpose in accordance with this privacy notice and applicable laws. If your personal data is no longer required, we will delete it or make it anonymous by removing all details that identify you. Otherwise, we will keep your personal data for as long as we have a relationship with you in order to respond to or process a request from you. 

If necessary, we may also retain your personal data for compliance with legal and accounting requirements or reporting obligations.

7. THIRD PARTIES WEBSITES 

Our website may contain links to other websites that we do not own or control. This notice does not cover them and we are not responsible for the privacy policies or practices of such third-party websites. We encourage you to review their privacy policies to find out how they collect, use or share your personal data.

8. YOUR RIGHTS AND CHOICES

Under the Jamaican Data protection Act, you have the right to request access to, and correct, and delete the personal data we hold about you, withdraw consent to processing or make a complaint, subject to any legal restrictions. Upon request, we will respond to your request within a reasonable timeframe, in compliance with applicable laws.

  It is your responsibility to provide accurate, correct, and complete information. If you notice any errors in your personal data or need to update it, please let us know through the contact details provided in this notice and we would take reasonable steps to correct it. 

You may instruct us not to process your personal data for marketing purposes at any time.  In practice, you would have expressly agreed in advance to our use of your personal data for marketing purposes with an opportunity to opt-out at any time.

For your protection, and to protect the privacy of others, we may need to verify your identity before completing what you have asked us to do.

Where we have relied upon your permission to use your personal data, and you later withdraw that permission, we may not be able to complete some of the purposes described in this notice.

9. DATA SECURITY

To make sure your personal data is not shared with or used by those not allowed to see it, we make use of appropriate technical, administrative, and physical safeguards to protect the personal data provided to us. We carefully choose service providers to work with, and check they have security measures and technologies in place to protect your personal data.

We will store all the personal data you provide on our secure firewall protected servers. All electronic transactions you make to or receive from us will be encrypted using SSL technology.

Unfortunately, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data, especially data transmitted electronically.

You are responsible for keeping your password and user details confidential. We will not ask you for your password.

10. INTERNATIONAL DATA TRANSFER

We may need to transfer your personal data to third-party providers outside of Jamaica. We implement appropriate measures to protect your personal data such as incorporating standard data protection clauses and perform those international transfers in accordance with the requirements of the law.

Please be aware that the data protection laws in the countries we transfer it to may not be the same as the laws in Jamaica. Law enforcement agencies, regulatory agencies, security authorities or courts in the countries we transfer your personal data to may have the right to see your personal information.

11. CHILDREN'S PRIVACY

We do not knowingly collect personal data from a child under the age of 18 without obtaining prior parental consent.

12. COOKIES, WEBSITE AND APPLICATION DATA

A cookie consists of data sent by a web server to a web browser and stored by the browser. The data is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.

We may use both "session" cookies and "persistent" cookies on the website.  We will use the session cookies to keep track of you whilst you navigate the website; We will use the persistent cookies to enable our website to recognize you when you visit;

Session cookies will be deleted from your computer when you close your browser. 

Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.

 
We use Google Analytics to analyze the use of this website.  Google Analytics generates statistical and other data about website use by means of cookies, which are stored on users' computers.  The data generated relating to our website is used to create reports about the use of the website. Google will store this data.  Google's privacy policy is available at: http://www.google.com/privacypolicy.html.

Our advertisers/payment services providers may also send you cookies.

Most browsers allow you to refuse to accept cookies.  For example, in Internet Explorer you can refuse all cookies by clicking "Tools", "Internet Options", "Privacy", and selecting "Block all cookies" using the sliding selector.  This will, however, have a negative impact upon the usability of many websites, including the ability to effectively process an order.

13. UPDATES TO THIS PRIVACY NOTICE

We may update this privacy notice from time-to-time by posting a new version on our website.  You should check this page occasionally to ensure you are happy with any changes.

We may also notify you of changes to our privacy notice via email if the changes are significant. 

14. HOW TO CONTACT US

If you have any questions about how we handle your personal data, please contact us at:

DATA PROTECTION OFFICER, FONTANA

12 West Kings House Rd, 

Kingston, Jamaica

dpo@fontanapharmacy.com

If you have a product or service that is offered by us with a third party, the third party may hold your personal data. If you have any questions or concerns, we will direct you to the appropriate party so that you may make enquiries as to that party’s privacy policies and practices.