Customer Privacy Policy


Introduction

Green Cross Health Limited ("Green Cross Health") respects the privacy of its clients, customers, staff, suppliers, and patients.

This Customer Privacy Policy (“Policy”) explains how we (Green Cross Health, our affiliates and related companies and other companies in which we have an ownership interest (together, "Green Cross Health Ltd")) collect and use your personal information for customer marketing purposes.This policy is closely linked to the overarching Green Cross Health Privacy Policy.

For the purposes of this Customer Privacy Policy, Green Cross Health includes any Unichem, Life Pharmacy, medical centres operating under "The Doctors" banner, and any of their affiliates.

For the purposes of applicable privacy legislation, the "Data Controller" in respect of your personal information is Green Cross Health Limited.

Personal information is any piece of information that relates to a natural person who can be identified, directly or indirectly. Given the nature of Green Cross Health's business, this may include a person's health information.

You authorise members of Green Cross Health to collect, use, and disclose your personal information in accordance with this Policy and also to the extent not prohibited by applicable legislation. We will manage your personal information in accordance with the terms of this Policy.

We will collect the personal information you provide us directly, and we may also collect personal information online from your computer, mobile or other device via our digital media platforms (including websites and apps). We may collect your personal information from a range of third parties and share your personal information (where we determine appropriate) with associated authorised third parties, including marketing, data storage and security service providers. We may also share your personal information within the wider Green Cross Health group for permitted purposes, including marketing and administration. We may also disclose your personal information to customs and immigration, governmental and law enforcement agencies. The sharing of your personal information will be subject to all applicable legislation, including the Privacy Act 2020 and the Health Information Privacy Code 2020.

If you are a Living Rewards member, or hold any customer account associated with us, we may also collect from and share your personal information with a range of third parties including our Living Rewards partners and our other third party business partners. We will deal with your personal information for a broad range of service provision and digital marketing purposes, including to facilitate the services you have requested, to better understand your preferences, and to generally conduct and develop our business.

If you choose not to provide us with the personal information that we request or require, then we may not be able to offer our services and products to you.

Where we collect personal information from you, we will store it in our secure data storage facilities in New Zealand.

Each time you utilise our services you will be confirming that the information supplied to us is current.

You are entitled to request access or correction to the personal information we hold about you. If you would like to request access or correction to your personal information that we hold, or if you have any questions or concerns in relation to your privacy, please contact us.

THE PERSONAL INFORMATION WE COLLECT ABOUT YOU

    Online information

    1. If you visit or use any Green Cross Health owned website, mobile application or mobile website, we and third parties may use cookies or other digital marketing technologies (such as tracking or analysis systems) to collect personal information about you from your computer, mobile or device. This information may include your contact details, domain name and IP address, and information about your online activity on our websites, such as web pages viewed, paths you used through our websites, options you selected, purchases, and any search terms you used.


    2. Health and other personal information

    2. We collect and use the personal information that you provide to Green Cross Health pharmacies (operating under the Unichem and Life Pharmacy banners), medical centres (operating under the Radius Medical and The Doctors banners) and the information that these affiliated businesses share with us relating to you (for example, your contact details and services used or procured by you). The personal information we may collect about you includes your name, address, date of birth, phone numbers, email address, and any other personal information you may volunteer (or which may be volunteered on your behalf) as part of your engagement with Green Cross Health members and/or persons employed by them.


    3. Information we receive from other sources (including social media)

    3. If you are a client, customer or patient of a member of the Green Cross Health, a Living Rewards member or if you hold any customer account associated with us, you acknowledge and agree that we may collect personal information about you, either from you directly or from third parties if the information is publicly or commercially available (such as via social media platforms). Such personal information will supplement our customer databases and will be used by us for marketing and business development purposes in accordance with this Policy.

    4. Health information

    4. We may request and collect (from you, or if the context so requires, your representative) your 'health information' (as defined in the Health Information Privacy Code 2020). Such information includes particulars about your health requirements, your medical and treatment history, disabilities or accidents/injuries, contact with any health or disability service providers and information about donations of blood or organs, for the purpose of helping us provide services to you and to fulfil your needs.

      We may disclose your health information to our agents and third parties (such as medical service providers or laboratory testing facilities) for the purpose of fulfilling your needs to the extent permitted, or as required, by law. Whenever you provide us with health information, you consent to the relevant member of Green Cross Health using your health information in accordance with this Policy.

      If you advise us that you do not want your health information disclosed to other entities within Green Cross Health (other than the Data Controller) then we will endeavour to fulfil your request to the full extent possible.


    5. Serious Medical and other occasions requiring collection or disclosure to third parties

    5. We may collect and disclose your personal information (including sensitive details about your physical and/or mental health) to third party medical, safety and/or security personnel if we believe that the collection or disclosure of the information is desirable to lessen or prevent a serious threat to any individual's life, health or safety or a serious threat to public health or public safety.


    6. Living Rewards

    6. If you are a Living Rewards member, we collect and use personal information about you. This includes the information you provide in your membership application, or in connection with your membership generally. We may collect personal information about you from third parties, including our business partners, to assist in identifying suitable offers and promotions that you may be interested in.


    7. Marketing Promotions and surveys

    7. If you enter a Green Cross Health competition or promotion, we will collect the personal information you provide as part of your entry. If you provide us with the names and contact details of any other people that you would like to have participate in our contests or promotions, we will also collect this information, and we draw your attention to section 5 below.

      If you complete a survey conducted by or on behalf of a member of Green Cross Health, we will collect information about you in your survey answers, including your name, unless you choose to answer anonymously.

    8. OUR PURPOSES FOR COLLECTING YOUR PERSONAL INFORMATION

    8. We may collect, hold, use and disclose your personal information for various purposes associated with service provision and digital marketing, including:

    • to assist in providing the services you request or require;
    • to conduct market, product or sales research, data processing and statistical analysis, and business improvement analysis;
    • to better understand your preferences so that we can improve our products and services to you;
    • to present you with information about suitable offers and promotions of goods and services (from us and our selected business partners) that might interest you;
    • to present you with survey requests and to obtain feedback in respect of our products and services;
    • to measure interest in and improve our products, services and websites;
    • to administer the Living Rewards programme;
    • otherwise to conduct and develop our business; and
    • any other use that you authorise.

    1. If deemed necessary, a unique identifier may be allocated to you in order for us to carry out one or more of our business functions.


    ELECTRONIC COMMUNICATIONS

    1. Unless you ask us not to use your personal information for marketing purposes, you acknowledge and agree that by providing us with your email address and/or phone number we and our third party business partners may send you electronic messages for the purposes set out in this Policy.
    1. You have the right to ask us not to collect, use or disclose your personal information for marketing purposes. You can exercise your right to ask us not to process your personal information for marketing purposes at any time by contacting us or by unsubscribing to our marketing emails.


    WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?

    1. We may disclose your personal information:
    • to members of Green Cross Health (including, for the avoidance of doubt, to employees of a member of Green Cross Health who are involved with the provision of services to you, or the administration and monitoring of the quality of services provided to you);
    • to authorised third party service providers to facilitate your specific requests or to assist us in providing products or services to you or improving our products or services;
    • to governmental agencies, law enforcement agencies, safety and security personnel, if required to do so by law, court order, or other legal process or where we are requested to do so by an authorised governmental or law enforcement authority;
    • to governmental, security, safety, law enforcement agencies and medical agencies if we believe in good faith that disclosure is desirable to lessen or prevent a serious threat to an individual's life, health or safety or a serious threat to public health or public safety;
    • to our professional advisers and business partners who support us in providing our products and services;
    • our assignees or potential assignees;
    • your nominated next of kin and/or general practitioner (if applicable to the services being provided to you); and
    • emergency services (if applicable to the services being provided to you).
    1. We may also disclose your personal information to third parties:
    • in the event that we buy or sell any business assets, in which case we may disclose your personal information to the prospective seller or buyer of such business assets;
    • if Green Cross Health (or any of its subsidiaries) or substantially all of its assets are acquired by a third party, in which case personal information held about its customers will be one of those transferred assets; and
    • if we are under a duty to disclose or share your personal information in order to comply with any legal obligation (to the extent not specified above) or in order to enforce or apply our terms and conditions.


    YOUR OBLIGATIONS REGARDING THE INFORMATION YOU PROVIDE US ABOUT OTHERS

    1. If you provide us with personal information about another person then you are responsible for ensuring you have authority to do so and that the person consents to our collection and use of their personal information as set out in this Policy. You must make that person aware that you have disclosed their personal information to us and that we will use their personal information in accordance with this Policy.


    WHAT HAPPENS IF YOU CHOOSE NOT TO PROVIDE US WITH YOUR PERSONAL INFORMATION?

    1. If you choose not to provide us with the personal information that we request or require, then we may not be able to offer or continue our services and products to you.
    1. If you do not provide us with the information we request or require, we may not be able to accept your membership application for Living Rewards membership, or continue your membership, or your entry into a promotion. We may not be able to provide you with Living Rewards member benefits.
    1. If you choose to limit the amount of personal information that can be collected by us from your computer, mobile or other device, you can do this by restricting cookies on your computer or device. However, this may significantly reduce the functionality of our websites and we may not be able to process your online requests or services.


    ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION

    1. Under the Privacy Act 2020, you are entitled to request access or correction to the personal information held by us. You may request access to the personal information that we hold about you by contacting us. We will respond to any such requests as required by law.
    1. Where applicable, we may charge a fee for responding to a request for access to and/or disclosure of personal information.


    CONTACTING US

    1. If you would like to contact us about anything in this Policy, including requests for access or correction to your personal information, inquiries, complaints, or questions about our handling of your personal information, please contact us as set out below.
    1. If you are making a complaint, you may also contact the Officer of the Privacy Commissioner (www.privacy.org.nz). Freephone (calling within New Zealand): 0800 803 909.
    1. Contact details:

      The Privacy Officer
      Email: privacy@greencrosshealth.co.nz

      Tel: +64 (0) 9 571 9080

      Green Cross Health Limited
      Private Bag 11906
      Ellerslie
      Auckland 1542
      New Zealand


    SECURITY

    1. We will take reasonable precautions to keep your personal information secure. However, you acknowledge and agree that you are solely responsible for the security of any online accounts you have with us and the security of your computer, mobile phone, tablet or other device. You acknowledge that the internet is inherently insecure. In sharing your personal information with us, you accept the risk that any information stored or transmitted on the internet or through email or any other digital channel may be intercepted or subject to unauthorised access or fraudulent behaviour by any other party.
    1. We will retain your personal information for as long as is necessary to carry out the purpose for which the information was collected, subject to the Health (Retention of Health Information) Regulations 1996.
    1. To protect your own privacy, you should not share your Living Rewards membership number, any account password information or personal identification numbers (PINs), mobile device passcodes, passwords or access codes with others including third party information aggregators, as the sharing of these details could enable others to access your personal account information on our websites.


    LINKS TO OTHER WEBSITES

    1. Green Cross Health websites may provide links to other related websites for your ease and convenience. These websites may have different security standards and privacy policies. We recommend that you read the privacy policies for these websites before deciding whether to divulge information to these websites. We are not responsible for the information you choose to divulge to these websites.


    CHANGES TO THIS PRIVACY POLICY

    1. We will make changes to this Policy from time to time. When we make changes, we will update the Policy on our websites and those changes will be effective immediately thereafter.