Effective Date: 16 September 2018
Personal data refers to all types of personal information, sensitive personal information, personal health information and privileged information. Personal information refers to “any information, whether recorded in a material from or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual”.
Who May Use the Services
The Garrod services are not directed to minors. We do not knowingly collect personal information online from minors and instruct minors not to send us any information to or through the Services.
Our services are designed for users from, and are controlled and operated by us from, the Philippines. By using the Services, you consent to the transfer of your information to the Philippines, which may have different data protection rules than those of your country.
The Personal Information We Collect
We want you to understand how personal information you provide to us is collected and used. We collect and store your personal information when you provide it to us or to our service providers, such as in the following situations:
Transactions: We or our service providers collect personal information from you when you enter into a transaction with us, such as when you refill a prescription or have your prescription order delivered to your home.
Registration: We collect your personal information when you register in our website, talk to our specialty pharmacist through different channels such as but not limited to: our social media accounts, messaging applications, text messages, phone/video call and face to face interaction.
Payment (Billing) Information: For all orders, we may ask for credit card, bank account, or other information necessary to process a payment from you. For your prescription orders, we may collect your prescription insurance information and any financial support information. We may also ask for your shipping or delivery information.
Storage: If you choose to create an online account, we will store payment, billing (including prescription insurance) and shipping information as a convenience to you for future purchases, and we will store information about your orders for order tracking and status retrieval purposes.
Contact Information: Garrod collects personal information from users of our services who are interested in receiving information about our products or services, such as e-mail alerts, newsletters, and other notifications.
Wellness or Fitness Information: We collect your personally identifiable wellness or fitness information if you give Garrod access to your wearable or connected device account.
Use and Disclosure of Personal Information
We use your personal information to respond to your requests, such as to fulfill your order, contact you with information about your order or prescriptions, send you email and app alerts, send you newsletters, and to provide you with related customer service. We may also use your information to send marketing communications and administrative information to you, including through the use of push notifications in our apps.
We may use and disclose your personal information to provide and coordinate the treatment and services you receive.
To enable us to comply with our corporate policies and with regulatory requirements, it is important that Garrod collects, uses, stores and retains your personal data when it is reasonable and necessary for a declared and specific purpose.
In general, we are using your data for any of the following purposes:
For you to have a better online shopping experience
For you to place an order and for us to identify and contact you, verify and confirm your order
For you to create a Garrod account and when you log-in, you will be able to:
- Store items in your shopping cart between visits,
- Proceed through checkout faster when making a purchase,
- Check the status of orders,
- View past orders,
- Check your accumulated points in your loyalty card,
- Make changes to your account information,
- Update your account profile, and
- Store alternative addresses (for shipping to multiple family members and friends)
For you to provide reviews in our products and services
For you to subscribe/unsubscribe to our e-newsletters
To generate statistical insights
To conduct research and analysis (through surveys or polls) in order to improve customer experience/satisfaction
To respond to specific complaints, inquiries, requests or to provide requested information
To provide customer care activities, monitor our quality and security, and provide services timely and efficiently and,
To notify and update you (through call, text or email) about our complimentary, commercial and promotional advertisements, loyalty and rewards offers, exclusive invites, discounts, surveys, and other direct marketing that we deemed relevant and beneficial to you based on your preference and interest initially provided to us or made aware of, with which you can opt-out anytime should you prefer not to receive these notifications.
To comply with Garrod’s obligations under law and as required by government organizations and/or;
To comply with legal and regulatory requirements or obligations; and,
To perform such other processing or disclosure that may be required under law or regulations.
We may disclose your personal information to other third parties, such as pharmacies, doctors, hospitals, other health care providers, pharmaceutical companies, schools and other partners to assist them in providing care to you or for your care coordination. In some instances, uses and disclosures of your personal information for these purposes may be made through reports or similar medical record or system.
We may use personal information to personalize your experience, including by presenting products and offers tailored to you, and for our business purposes, such as research, data analysis, audits, fraud monitoring and prevention, developing our services and new products and services, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.
In the event that Garrod or some or all of our business, assets or stock are sold or transferred (including in connection with any bankruptcy or similar proceedings) or used as security, or to the extent we engage in business negotiations with third parties, personal information may be transferred to or shared with third parties as part of any such transaction or negotiation.
To the extent permitted by applicable law, we may provide personal information to our affiliated businesses or to our business partners, who may use it for research, data analysis and to send you marketing and other communications.
We may disclose personal information to our service providers, who provide services such as website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
If you add a payment card to an application or software operated by us, we will share information you provide about your card with our service providers and/or your card issuer to facilitate providing the services to you.
We may disclose your personal information to law enforcement officials as permitted or required by law. In matters involving claims of personal or public safety or in litigation where the information is pertinent (including to allow us to pursue available remedies or limit the damages that we may sustain), we may use or disclose personal information, including without court process. We may also use or disclose personal information to enforce our terms and conditions, to protect our operations or those of any of our affiliates, or to protect our rights, privacy, safety or property and/or that of our affiliates, you, or others.
We may use and disclose personal information to investigate security breaches or otherwise cooperate with authorities pursuant to a legal matter.
We may use and disclose information that does not personally identify you (including the information described under “Cookies and Other Technologies,” below) for any purpose, except to the extent limited by applicable law. If we are required to treat such information as personal information under applicable law, then we may use it for all the purposes for which we use and disclose personal information.
We may combine information that does not personally identify you with personal information. If we do, we will treat the combined information as personal information as long as it is combined.
For example, if you utilize a social media feature such as the Facebook "Like" button, Google Plus, Pinterest or a Twitter widget, these features may collect information about your IP address and which page you're visiting on our site, and they may set a cookie or employ other tracking technologies. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with those features are governed by the privacy policies of the companies that provide them.
We may display targeted ads to you through social media platforms. These ads are sent to groups of people who share traits, such as where they live or have expressed an interest in shopping in our site. We do not share any of your personally identifiable information, including your shopping history or health information, with social media platforms. See the policies of each social media platform for additional information about these types of ads, including how to manage your display settings for these ads.
In addition, we are not responsible for the information collection, use, disclosure, or security policies and practices of other organizations, such as Apple, Google, Microsoft, or any other app developer, app provider, operating system provider, wireless service provider, or device manufacturer.
We seek to use reasonable physical, technical, and administrative safeguards to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is not secure, please immediately contact us in accordance with the “Contact Information” section below.
You are responsible for maintaining the confidentiality of your Services access information and password and for restricting access to your device, and you agree to accept responsibility for all activities that occur under your password.
Cookies and Other Technologies
Cookies are small text files we transfer to your computer or other device. These small files help us to personalize content on our pages and provide programs like e-coupons. Your browser software can be set to reject or accept cookies. Instructions for resetting the browser are available in the Help section of most browsers.
We may use third-party advertising companies to display advertisements regarding goods and services that may be of interest to you when you access and use the Services, based on information relating to your access to and use of the Services and other online services. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). If you would like more information about this practice and to learn about your choices in connection with it, please visit https://www.networkadvertising.org/managing/opt_out.asp and https://www.aboutads.info/.
We do not respond to browser do-not-track signals.
We and our service providers may collect the physical location of your device by, for example, using satellite, cell phone tower, WiFi signals, beacons, Bluetooth, and near field communication protocols, when you are in or near a Garrod Specialty Pharmacy store. We may use your device’s physical location to provide you with personalized location-based services and content, including for marketing purposes. We may also use such information to understand traffic patterns in, near, and across our store locations. We may share aggregated statistics derived from the location and other information we collect with advertisers and other third parties. You may be permitted to allow or deny such collection of your device’s location, such as through the settings on your mobile device and/or, to avoid the collection of location by beacons, by disabling Bluetooth. If you choose to deny such collection, we and our service providers may not be able to provide you with certain personalized services and content.
Fraudulent Sites, Spam & Phishing
Please be aware that there may be fraudulent websites that illegally use Garrod logos, and other aspects of the Garrod brand. Garrod is in no way associated with any fraudulent websites. These sites may circulate their presence on the internet via spam email, or through fraudulent phishing practices.
These sites have not been authorized by Garrod to use our name and we work aggressively to identify their source and have them shut down. If you are in receipt of this type of spam email, to help protect your privacy you should avoid replying to it or forwarding it to other people.
In addition to our official websites, Garrod works with a number of third parties that host websites and micro-sites that provide information and services to our customers. If you are concerned that a website or an email may be fraudulent, please contact us by phone at +63917 3144763 with your concerns.
We keep and protect your personal data using a secured server behind a firewall, deploying encryption on computing devices and physical security controls.
We restrict access to your personal data only to qualified and authorized personnel who hold your personal data with strict confidentiality.
We reveal only the last four digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.
Any personal data that you provide on the website is initially processed and stored by Garrod. Using a secured connection, only authorized Garrod personnel or service provider can then access and download your personal data from the Garrod.
It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign-off when finished using a shared computer.
Storage and Retention of data
Garrod reserves the right to retain your personal data in our files located in the Philippines and Singapore under certain circumstances such as when your personal data may be necessary to resolve disputes, or if Garrod is required to do so by law or in the good faith; provided that such action is necessary to comply with a legal obligation and/or protect and defend the rights or property of Garrod. or its affiliates. If Garrod is required to retain any portion of your personal data for such purposes, it shall use reasonable efforts to limit such data to what is necessary to accomplish the particular purpose.
Your Choices and Access
You can take yourself off our email list, by contacting Garrod at +63917 314 4763 or sending an email to firstname.lastname@example.org.
You may stop the receipt of push notifications through your mobile device settings.
You can request the removal or modification of the personal information you have provided to us by contacting Garrod at +63917 3144763 or sending an email to email@example.com.
For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity and obtain information on the context in which you provided your personal information before implementing your request. We will try to accommodate your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
Deidentified Patient Information
In addition to personal information, we may sell or disclose patient and/or member information that has been deidentified as permitted by law. To the extent we sell or share such deidentified patient and/or member information, we do so pursuant to one of the deidentification methodologies described in Section 164.514(b)(1) or (b)(2) of Title 45 of the Code of Federal Regulations, commonly known as the HIPAA expert determination method and the HIPAA safe harbor method, respectively.
By establishing a Garrod account, you agree that it is your responsibility to:
Authorize, monitor, and control access to and use of your Garrod account, User ID and password.
Promptly inform us of any need to deactivate a password or an account by calling +63917 3144763.
If you have any questions or concerns about this statement, or about the way your information is collected and used, please call us at +63917 314 4763.
Garrod Specialty Pharmacy
Attention: Data Privacy Officer
Address: 19 Chestnut corner Dogwood Street, Greenwoods Executive Village, Cainta Philippines 1900
Date. This Notice is effective as of 16 Sept 2018.
Personal Health Information Notice
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
This describes the privacy practices of Garrod and the members of its affiliates, if any.
Personal health information (PHI) is information about you that we obtain to provide our services to you and that can be used to identify you. It includes your name and contact information, as well as information about your health, medical conditions and prescriptions. It may relate to your past, present or future physical or mental health or condition, the provision or health care products and services to you, or payment for such products or services.
We are required by law to protect the privacy of your PHI and to provide you with this notice on our website explaining our legal duties and privacy practices regarding your PHI. This Notice describes how we may use and disclose your PHI. We have provided you with examples; however, not every permissible use or disclosure will be listed in this Notice. This Notice also describes your rights and the obligations we have regarding the use and disclosure of your PHI. We and our employees and workforce members are required to follow the terms of this Notice or any change to it that is in effect. We are required to follow privacy laws when they are stricter (or more protective of your PHI). Note that some types of sensitive PHI, such as HIV information, genetic information, alcohol and/or substance abuse records, and mental health records may be subject to additional confidentiality protections.
Uses and Disclosures of Your PHI for Treatment, Payment and Health Care Operations.
We may use and disclose your PHI for treatment, payment and health care operations without your written authorization. The following categories describe and provide some examples of the different ways that may use and disclose your PHI for these purposes:
Treatment: We may use and disclose your PHI to provide and coordinate the treatment, medication and services you receive. For example, we may:
Use and disclose your PHI to provide and coordinate the treatment, medication and services you receive in Garrod Inc.
Disclose your PHI to other third parties, such as pharmacies, doctors, hospitals, or other health care providers, government agencies and foundations or support group and to assist them in providing care to you or for care coordination. In some instances, uses and disclosures of your PHI for these purposes may be made through a Health Information Exchange or similar shared system.
Contact you to provide treatment-related services, such as refill reminders, adherence communications, or treatment alternatives (e.g., available generic products).
Payment: We may use and disclose your PHI to obtain payment for the services we provide to you and for other payment activities related to the services we provide. For example, we may:
Share your PHI with your insurer, pharmacy benefit manager, or other health care payor to determine whether it will pay for your health care products and services you need and to determine the payment amount you may owe.
Contact you about a payment or balance due for prescriptions dispensed to you at Garrod Specialty Pharmacy or may disclose your PHI to other health care providers, health plans who may need it for their payment activities.
Health Care Operations: may use and disclose your PHI for health care operations – those activities necessary to operate our health care business. For example, we may:
Use and disclose your PHI to monitor the quality of our health care services, to provide customer services to you, to resolve complaints, and to coordinate your care.
Transfer or receive your PHI if we buy or sell pharmacy locations.
Use and disclose your PHI to contact you about health-related products, services or opportunities that may interest you, such as programs for Garrod patients.
Disclose your PHI to other entities that have provided services to you so that they can improve the quality and efficacy of the health care services they provide or for their health care operations.
Use your PHI to create de-identified data, which no longer identifies you, and which may used or disclosed for analytics, business planning or other purposes
Partners: Our partners such as but not limited to pharmaceutical companies, schools, government agencies, online store platforms, software applications may use your de-indentified PHI for research, data analysis and other activities necessary for their operations.
Other Uses and Disclosures of Your PHI that Do Not Require Authorization
We are also allowed or required to share your PHI, without your authorization, in certain situations or when certain conditions have been met.
Business Associates: When we contract with third parties to perform certain services for us, such as billing or consulting, these third party service providers, known as Business Associates, may need access to your PHI to perform these services. They are required by law and their agreements with us to protect your PHI in the same way we do.
Individuals Involved in Your Care or Payment for Your Care: We may disclose your PHI to a friend, personal representative, family member, or any other person you identify as a caregiver, who is involved in your care or the payment related to that care. For example, we may provide prescriptions and related information to your caregiver on your behalf. We may also make these disclosures after your death unless doing so is inconsistent with any prior expressed preference documented by Garrod. Upon your death, we may disclose your PHI to an administrator, executor, or other individual authorized under law to act on behalf of your estate. If you are a minor, we may release your PHI to your parents or legal guardians when permitted or required by law.
Workers' Compensation: We may disclose your PHI as necessary to comply with laws related to workers' compensation or similar programs.
Law Enforcement: We may disclose your PHI to law enforcement officials as permitted or required by law. For example, we may use or disclose your PHI to report certain injuries or to report criminal conduct that occurred on our premises. We may also disclose your PHI in response to a court order, subpoena, warrant, or other similar written request from law enforcement officials.
Required by Law: We will disclose your PHI when required to do so to comply with federal, state or local law.
Judicial and Administrative Proceedings: We may disclose your PHI in response to a court or administrative order, subpoena, discovery request, or other lawful process.
Public Health and Safety Purposes: We may disclose your PHI in certain situations to help with public health and safety issues when we are required or permitted to do so, for example to: prevent disease; report adverse reactions to medications; report suspected abuse, neglect or domestic violence; or to prevent or reduce a threat to anyone’s health or safety.
Health Oversight Activities: We may disclose your PHI to an oversight agency for certain activities including audits, investigations, inspections, licensure or disciplinary actions, or civil, administrative, and criminal proceedings, and as necessary for oversight of the health care system, government programs, or compliance with civil rights laws.
Research: Under certain circumstances, we may use or disclose your PHI for research purposes. For example, we may use or disclose your PHI as part of a research study when the research has been approved by an institutional review board and there is an established protocol to ensure the privacy of your information.
Coroners, Medical Examiners and Funeral Directors: We may disclose PHI to coroners, medical directors, or funeral directors so that they can carry out their duties.
Organ or Tissue Donation: We may disclose your PHI to organ procurement organizations.
Notification: We may use or disclose your PHI to notify or assist in notifying a family member, personal representative, or any other person responsible for your care regarding your location, general condition, or death. We may also disclose your PHI to disaster relief organizations so that your family or other persons responsible for your care can be notified of your location, general condition, or death.
Correctional Institution: If you are or become an inmate of a correctional institution, we may disclose your PHI to the institution or its agents to assist them in providing your health care, protecting your health and safety or the health and safety of others.
Specialized Government Functions: We may disclose your PHI to authorized government officials for the conduct of military, national security activities and other specialized government functions.
Uses or Disclosures for Purposes that Require Your Authorization
Use and disclosure of your PHI for other purposes may be made only with your written authorization and unless we have your authorization we will not:
Use or disclose your PHI for marketing purposes.
Sell your PHI to third parties (except for in connection with the transfer of a business to another health care provider).
Share psychotherapy notes (to the extent we have any).
You may revoke your authorization at any time by submitting a written notice to our Data Privacy Officer. Your revocation will be effective upon receipt; however, it will not undo any use or disclosure of your PHI that occurred before you notified us, or any actions taken based upon your authorization.
Your Health Information Rights
Written Requests and Additional Information: you may request additional information about Garrod’s privacy practices or obtain forms for submitting written requests by contacting the Garrod Data Privacy Officer.
Obtain a Copy of this Notice: You have the right to obtain a paper copy of our current Notice at any time. You may do so by going to the site where you obtain health care services from us or by contacting the Garrod Data Privacy Officer.
Inspect and Obtain a Copy of Your PHI: With a few exceptions, you have the right to see and get a copy of the PHI we maintain about you. You may request access to your PHI electronically. To inspect or obtain a copy of your PHI, submit a written request to the Garrod Data Privacy Officer. You may also ask us to provide a copy of your PHI to another person or entity. A reasonable fee may be charged for the expense of fulfilling your request as permitted. We may deny your request to inspect and copy your record in certain limited circumstances. If we deny your request, we will notify you in writing and let you know if you may request a review of the denial.
Request an Amendment: If you feel that the PHI we maintain about you is incomplete or incorrect, you may request that we amend it. For example, if your date of birth is incorrect, you may request that the information be corrected. To request an amendment, submit a written request to the Garrod Data Privacy Officer. You must include a reason that supports your request. If we deny your request for an amendment, we will provide with you a written explanation of why we denied it.
Receive an Accounting of Disclosures: You have the right to request an accounting of disclosures we make of your PHI for purposes other than treatment, payment, or health care operations. Please note that certain other disclosures need not be included in the accounting we provide to you. To obtain an accounting, submit a written request to the Garrod Data Privacy Officer. We will provide one accounting per 12-month period free of charge, but you may be charged for the cost of any subsequent accountings. We will notify you in advance of the cost involved, and you may choose to withdraw or modify your request at that time.
Request Confidential Communications: You have the right to request that we communicate with you in a certain way or at a certain location. For example, you may request that we contact you only in writing at a specific address. To request confidential communication of your PHI, submit a written request to the Garrod Data Privacy Officer. Your request must state how, where, or when you would like to be contacted. We will accommodate all reasonable requests.
Request a Restriction on Certain Uses and Disclosures: You have the right to request additional restrictions on our use and disclosure of your PHI by sending a written request to the Garrod Data Privacy Officer. We are not required to agree to your request except where the disclosure is to a health plan or insurer for purposes of carrying out payment or health care operations, is not otherwise required by law, and the PHI is related to a health care item or service for which you, or a person on your behalf, has paid in full out-of-pocket. If you do not want a claim for payment submitted to your health plan on record, please discuss with the pharmacist or health care provider when you check in for care or before your prescription is sent to the pharmacy.
Notification of Breach: You have a right to be notified in the event there is a breach of your unsecured PHI.
To Report a Problem
Complaints: If you believe your privacy rights have been violated, you can file a complaint with the Garrod Data Privacy Officer. All complaints must be submitted in writing. You will not be penalized or otherwise retaliated against in any way for filing a complaint.
Changes to this Notice
We reserve the right to make changes to this Notice as permitted by law and to make the revised Notice effective for PHI we already have about you as well as any information we receive in the future, as of the effective date of the revised Notice. If we make material or important changes to our privacy practices, we will promptly revise our Notice. Upon request to the Garrod Data Privacy Officer, Garrod will provide a revised Notice to you. We will also post the revised Notice in our retail stores and on our Websites at and will make copies available at our facilities and locations where you receive health care products and services from us.
Effective Date. This Notice is effective as of 16 September 2018