When you use Anna, you are trusting us with your information. We take your privacy seriously.
This policy outlines the types of information we collect, why we collect it and how you can manage, update and delete the information we hold.
1.1 Create and link high quality information about various aspects of male and female fertility; and
- 1.2 Facilitate confidential consultations between our customers and:
- Registered Philippine health practitioners, including medical practitioners, nurses, and midwives (Partner Practitioners);
- (Allied support and companion persons, such as trained doulas (Partner Companions); and
Other Philippine registered health providers who provide fertility services, such as pathology providers and pharmacists (Partner Providers).
Anna is bound by the Privacy Act of the Philippines.
Anna collects a range of information, including personal information about you. Personal information includes information or an opinion about you (whether true or not), which identifies you or from which you are reasonably identifiable.
How we collect your personal information
We will collect and hold your personal information in a lawful and fair manner, and not in an intrusive way.
Where it is reasonably practical to do so, we will collect your personal information directly from you. Our Partners may also collect and hold your personal information, including your health information.
We collect your personal information directly from you when you:
- 2.1visit the Website and sign up as a subscriber to Anna content;
- 2.2make an inquiry or order in relation to goods or services through our Website, including when you order pregnancy supplements through our Website;
- 2.3attend an online consultation with a Partner Doctor or Partner Provider through the Website. We note your treating practitioner will make, hold and maintain your medical records. However, with your written consent, Anna may also hold notes made and results generated by your Partner Doctor or Partner Providers. Any health information held by Anna will be managed in accordance with the Health Records and Information Privacy Act 2002 (NSW) or other relevant State legislation;
- 2.4undergo tests with Partner Providers. For instance if you undergo tests with a partner pathology service, your results will be passed to Anna so that we can facilitate your next appointment with a Partner Practitioner;
- 2.5contact us via telephone or facsimile;
- 2.6correspond with us, including when you complete our online form, contact us through our Website or write to us by email or on paper;
- 2.7upload your personal information on any mobile applications operated by Anna;
- 2.8complete a customer satisfaction and market research survey; and/or
- 2.9participate in any of our services.
- We may also collect your personal information:
- 2.1from you or third parties when administering and performing any contracts with service providers; and
- 2.2from publicly available sources and third parties, such as suppliers, recruitment agencies, contractors, our clients and business partners; and
- 2.3from you when you attend an online consultation with a Partner through the Website. We note your treating practitioner will make, hold and maintain your medical records. However, with your written consent, Anna may also hold notes made and results generated by your Partners. Any health information held by Anna will be managed in accordance with the Health Records and Information Privacy Act 2002 (NSW) or other relevant State legislation;
- If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding your information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.
Types of personal information we collect
The types of personal information we collect include (but are not limited to): your name, postal address, email address, contact phone numbers, date of birth, Medicare information, billing and shipping information, device ID, IP address, statistics on page views, traffic, standard web log-in information, details of the services and Partners you make enquiries about, written consents related to the services we facilitate and, if applicable, employment information.
We will collect and hold sensitive health information about you, such as your medical history, height, weight, current medications, frequency of your menstrual period, your symptoms (including whether you have a hairy face, acne, painful periods, paid during intercourse), whether you smoke, whether you have any history of Sexually Transmitted Infections, your family planning goals (including how many children you are hoping to have and when), your family planning history, your current fertility status and any other information you provide to Partners. The sensitive heath information we collect about you is provided to your treating Partner Practitioner, Partner Companions, and Partner Providers from whom you request services, in accordance with your written consent. We only collect sensitive health information about you with your consent, or otherwise in accordance with the Privacy Act.
Where you do not wish to provide us with your personal information, we may not be able to facilitate the requested services or provide the goods you order.
Our purposes for handling your personal information
We collect, hold, use and disclose personal information to:
- 4.1offer and provide you with our goods and services;
- 4.2manage and administer those goods and services, including account keeping procedures;
- 4.3provide facilities to Partners using Anna so that they can arrange consultations with you and provide you with their professional services;
- 4.4communicate with you about a number of matters, including but not limited to, the services you have sought, dispatch and track information, returns and exchange authorisations, as well as to follow-up a matter with you at the request of the Partner or to email you tax invoices;
send you marketing or promotional information in relation to Anna or any of Anna's group companies or business partners that might be of interest to you (including via SMS, email and personalised website experiences, such as a dashboard of recommendations for health products and services which may benefit you);
improve Anna or any of Pulse 63 group companies’ products and services, including research and development;
- 4.7 comply with our legal and regulatory obligations;
4.8 consider you application for employment (if applicable);
- 4.9otherwise to manage our business.
Disclosure of personal information
We disclose personal information between Anna group companies and third parties such as our suppliers, organisations that provide us with technical and support services, or our professional advisors, where permitted by the Privacy Act. If we disclose information to a third party, we require that the third party protect your information to the same extent that we do.
- 5.1 Partner Practitioners;
- 5.2 Partner Companions;
- 5.3 Partner Providers
- 5.4 Cloud service providers; and
- 5.5 Payment system operators (such as Shopify).
- We will not use or disclose your personal information for any other purpose unless you have consented to that use or disclosure.
Protection of personal information
We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, as records on third party servers, which may be located overseas.
We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information. This also applies to disposal of the personal information.
We further protect personal information by restricting access to your personal information to only those who need access to the personal information to do their job. Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your personal information.
We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.
Like most businesses, marketing is important to our ongoing success. We believe we have a unique range of products and services that we provide to customers at a high standard. Therefore we like to stay in touch with customers and let them know about new opportunities. We may provide you with information about new products, services and promotions either from us, or from third parties which may be of interest to you.
We will not disclose your personal information to third parties for marketing purposes without your consent.
You may opt out at any time if you no longer wish to receive marketing messages from us. You can make this request by unsubscribing from all future marketing messages by following the unsubscribe link included in our marketing material or by contacting our Privacy Officer.
Accessing and correcting your personal information
You may contact our Privacy Officer to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. On the rare occasion when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to any of the personal information about you held by us.
We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusal.
We will respond to all requests for access to or correction of personal information within a reasonable time.
Overseas transfers of personal information
From time to time we may engage an overseas recipient to provide services to us, such as cloud-based storage solutions. Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider. However, by providing us with your personal information, you consent to the storage of such information on overseas servers (such as servers located in the United States of America) and acknowledge that Philippine Privacy Principle 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the APPs, that entity will not be bound by, and you will not be able seek redress under, the Privacy Act.
If in future we do propose to disclose personal information overseas other than as above, we will do so in compliance with the requirements of the Privacy Act. We will, where practicable, advise you of the countries in which any overseas recipients are likely to be located.
If you do not want us to disclose your information to overseas recipients, please let us know.
Resolving personal information concerns
The Privacy Officer: Ina Gatan
Your experience with Anna is important to us. We endeavor to respond to any complaint within a reasonable period.