PRIVACY POLICY
1. Introduction
1.1. REFORMR HEALTH LIMITED (“Reformr”, “the Company”, “we”, “us”, or “our”) is an online platform, committed to providing health services.
1.2. Reformr is committed to protecting the privacy of individuals who use our website and services, including any applications. This Privacy Policy (“Policy”) sets forth the protocol of Reformr for the collection, use, disclosure, protection, and amendment of personal information.
1.3. This Policy intends to comply with the Health Information Privacy Code 2020 (“HIPC”), the New Zealand Privacy Act 2020, the Health Act 1956, and any other applicable codes or regulations created pursuant to this legislation. We are committed to act in accordance with relevant New Zealand legislation, as it relates to the protection of personal information.
2. Definitions
2.1. Any reference to “Personal Information” made in this Policy includes, but is not limited to, your name, gender, date of birth, contact details, and your medical history.
2.2. When this Policy refers to “De-Identified Information”, it is referring to information that is not intended to be used to personally identify an individual.
2.3. Reformr’s “Care Team” includes, but is not limited to, our doctors, pharmacists, and other staff dedicated to provided health services to you.
3. Children Under Age 16
3.1. Reformr does not knowingly collect information from children under the age of 16.
3.2. You must be over the age of 18 to use Reformr’s services.
4. Collection of Personal Information
4.1. Where reasonably practicable to do so, Reformr collects your personal information directly from you.
4.2. Collection of your personal information occurs when you:
4.2.1. Sign up as a subscriber to Reformr’s content;
4.2.2. Participate in an online consultation, whether by messaging service, email, telephone, or video;
4.2.3. Message our Care Team;
4.2.4. Create an online account on our website or on any application operated by us;
4.2.5. Make a payment to Reformr – your account name, number, type, balance and address may by disclosed to us;
4.2.6. Complete a Customer Satisfaction or Market Research Survey;
4.2.7. Make an inquiry or order;
4.2.8. Correspond with us, through the form of writing to us, emailing us, completing online quizzes or forms, or similar platforms; or
4.2.9. Participate in any of Reformr’s health services.
5. Types of Personal Information Collected
5.1. Contact Information
5.1.1. This includes, but is not limited to, your name, postal address, residential address, email address, contact phone numbers, date of birth, and identification documents such as passport or driver’s licence details.
5.2. Health Information
5.2.1. This includes, but is not limited to, your medical history and health records, health status and test results, laboratory testing results, diagnostic images, and other health-related information.
5.3. Billing Information
5.3.1. This includes, but is not limited to, your bank account number, account holder name(s), bank account type, bank account balance, address, online banking security credentials.
5.3.2. Your payment information is collected, but not stored, unless you give Reformr express consent to do so. This may happen if you wish to set up recurring payments for a subscription service. In that case, only information necessary to transact payments will be stored.
5.4. Message Information
5.4.1. This includes, but is not limited to, any information sent via Reformr’s online messaging platforms.
5.5. Device Information
5.5.1. This includes, but is not limited to, your location, IP address, session information and cookies.
5.6. Online Analytics
5.6.1. This includes, but is not limited to, analytics from your activities on our website and any application Reformr operates.
6. Purposes of Collecting Personal Information
6.1. Reformr collects, stores, uses and discloses personal information for the purpose of:
6.1.1. Offer and providing online health services;
6.1.2. Communicating with users and potential users of our services;
6.1.3. Complying with any legal or regulatory obligations, exercise and defend our legal rights, and review and resolve complaints or disputes;
6.1.4. Facilitate and authorise payment and processing via third party gateways;
6.1.5. Facilitate third parties communicating with you;
6.1.6. Anything relating to a merger, acquisition, organisational restructure, financing, sale of assets, bankruptcy or insolvency event;
6.1.7. Applications for employment; or
6.1.8. Otherwise for general business management, including, but not limited to, notifying medical defence organisations, our insurers, quality assurance and data processing and handling.
7. Disclosure of Personal Information
7.1. Subject to any applicable legal or regulatory restrictions, we may disclose Personal Information that we have collected:
7.1.1. As required by law, which can include any information as required by subpoena or court order;
7.1.2. To our employees, contractors, service providers and third parties that are used to assist in the provision of our services;
7.1.3. To our subsidiaries and affiliates;
7.1.4. Where we have a sincere belief that disclosing information is required to protect your safety or the safety of others, to uphold our own rights, to investigate fraud, or to comply with a government request;
7.1.5. To a buyer or successor in the event of a merger, acquisition, divestiture, organisation restructure, dissolution or other sale or transfer of some or all of Reformr’s assets, whether as part of bankruptcy, liquidation or similar proceeding or sale, in which Personal Information is among the assets transferred; and
7.1.6. For any other purpose disclosed when the information is collected.
8. Notifications
8.1. Reformr will conduct itself pursuant to Section 74 of the Health Act 1956, whereby health practitioners are required to report to the medical officer of health any patient they have ‘reasonable suspicion’ is suffering from a notifiable disease.
8.1.1. Reformr will not conduct specific testing in relation to this legal obligation but will fulfil its requirements to report may the situation arise.
9. Cookies, Device IDs, and other Tracking Information
9.1. Reformr may use cookies, device IDs and other tracking technologies to improve the use experience and personalise content, including advertisements.
9.1.1. A “cookie” is a small piece of information stored on your device for a pre-determined time period.
9.2. Reformr uses cookies to help keep track of items uses place in their shopping carts, including when users abandon their carts. This information is used to determine when to sen cart reminder messages via SMS.
9.3. Users may disable cookies or other tracking technologies via their browser settings.
10. De-Identified Information
10.1. Reformr may use De-Identified Information collected by us without restriction.
11. Information Shared With Third Parties
11.1. This Privacy Policy applies to Personal Information collected in accordance with this Policy.
11.2. Links present on our website, email correspondence, chat messages or elsewhere may lead you to platforms run by third parties. We are not responsible for the security practices of third parties, and we encourage you to read their privacy policies.
11.3. The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.
12. Information Shared With Us About Third Parties
12.1. In the case that you disclose the Personal Information of a third party, you are personally responsible for ensuring you have the authority and consent to do so and that that consent extends to our collection and use of their Personal Information in accordance with this Policy.
13. Accessing and Amending Personal Information
13.1. As per the Privacy Act 2020, and Rules 6 and 7 of the HIPC, you have the right to access and amend the Personal Information held by us.
13.2. You may request access to your Personal Information by contacting us. As required by law, we will respond to any such requests.
13.3. Where applicable, we may charge a fee for responding to a request for access.
13.4. Where applicable, we may charge a fee for the disclosure of Personal Information.
14. Retention of Personal Information
14.1. Reformr is required by the Health (Retention of Health Information) Regulations 1996 to retain Health Information for a minimum of 10 years beginning on the day after the date shown in the health information as the most recent date on which a provider provided services to the individual.
14.2. When Reformr deletes Personal Information, it will be deleted from the active database, but may remain in archives insofar as to comply with legal requirements.
14.2.1. Reformr may also retain De-Identified Information about your use of the services.
14.3. Personal Information that has been disclosed to third parties in accordance with this Policy may not be able to be accessed, deleted, or modified by Reformr.
15. Security
15.1. Reformr takes reasonable precautions and measures to keep your Personal Information secure.
15.2. By using our services, you acknowledge that you hold full responsibility for the security of any online accounts you hold with us, as well as the security of your computer, mobile phone, tablet or any other device. It is important to note that internet is inherently insecure, and you therefore acknowledge that any Personal Information shared with us carries a risk of interception, unauthorised access or fraudulent behaviour by any third party.
15.3. Reformr cannot guarantee the security of any information you disclose to us, and you acknowledge that you are responsible for the risk associated with doing so.
16. Questions, Complaints and Concerns
16.1. Any questions, complaints or concerns about this Privacy Policy should be directed to:
The Privacy Officer
REFORMR HEALTH LIMITED
PO Box 111
11 Auckland Street
Auckland 1023
17. Changes to This Privacy Policy
17.1. Reformr reserves the right to make amendments of the terms of this Policy, without notice. A current copy of our Privacy Policy will be available on our website and periodic checking of our website will ensure you are aware of the up-to-date Policy.
17.2. This Policy was updated on 5 March 2023.