Privacy Policy

1. What personal data do we use?

What is personal data?

Personal data is any data relating to a person who is identified or who can be identified (such as a name, an identification number, or an online identifier).
Personal data you give us: You may give us personal data about you by filling in forms on, or interacting with, the PharmaFlexi App, our website, or by corresponding with us by phone, email or otherwise. Examples of personal data include:

  • name, address, email address and phone number.
  • information about your budgets.
  • personal data about your financial circumstances.
  • content you share with us in our community (Facebook, Twitter etc) or via our social media channels or via our Customer Care.
  • Copies of personal identification documents (such as your Passport, ID, Driver License).
  • Personal information required to identify you and verify the information you give us.
  • Biometric data (such as fingerprint or facial recognition data) to grant access to our app on your device.

Personal data we collect from you:

When you use the PharmaFlexi App or our website we may – ourselves or through our partners - collect information such as:

  • P address
  • device details
  • your login information
  • information about each visit you make to the PharmaFlexi App (such as page response times and length of visit)
  • location data
  • info about your use of the PharmaFlexi App or website through tracking tools
  • information we require to comply with our legal and regulatory obligations
  • information to verify the data you give us
  • information from your phone (like contact details from your address book)

We use well-known advertising platforms such as Facebook and Google to tell you about the Pharma Flexi App:

  • If you click through such an advert and agree to the PharmaFlexi App Terms of Use, an automated process will confirm to the advertising platform that you have signed up to the PharmaFlexi App and how much you use the PharmaFlexi App.
  • If you don’t use these platforms we will not collect or process this data.

We use tools to improve the user experience of our website and to personalise your PharmaFlexi App experience. Therefore, we perform statistical analyses about the way you use the services of Yolt.

2. What do we use your personal data for?

Contractual performance:

If you download our app and want us to deliver you our services, we can only perform these services if we can process your personal data for this purpose.

Legitimate interest:

We use your personal data on the basis of our legitimate interest and to your benefit so that we can:

Identification and Verification

  • Create a persona about you, so:
    • We can give you relevant insights and suggest relevant Actions for you
    • We can deliver you the benefit of our app and connect you to our services and the services and products of our Partners
  • Provide you with updates about the PharmaFlexi App;
  • Improve your experience of our service:
    • Assess the use of the PharmaFlexi App;
    • Help us identify people like you that might enjoy the PharmaFlexi App;
  • Make a secure connection between your device and the PharmaFlexi App
  • Take action if we need to defend our rights under the PharmaFlexi App Terms if you would misbehave or act in deviation of laws or regulations or the PharmaFlexi App Terms
  • Track and examine the use of the PharmaFlexi App and the website to prepare reports on its activities and analyse that data
  • Attract new partners and get you the best deals available from our partners
  • Perform research and trend analysis to optimise your experience;
    • Creating content using some personal data will enable us to engage with you in a relevant and human way.
    • Using and presenting content based on data provides an ideal way to talk to you about the benefits of the PharmaFlexi App and its features in an engaging and relatable way and link you back to the benefit of the product.
  • Engage and activate our users by:
    • Learning from beta services
    • Re-engaging our users on social media and via email
    • Providing more detailed information on your spending data. e.g. a weekly or monthly email on personalised insights
  • Optimize your experience in the Partner Platform by:
    • Suggesting you partners or products and services in the Partner Platform that might interest you
    • Based on your interests and our Smart Insights offering you deals or promotions of our partners
    • Reusing and prefilling data you have provided us with before when you connect a new partner or new product or service in the Partner Platform. We do so to avoid asking you the same data twice and you can always validate and update this data.
  • We could use your personal data in an anonymised and aggregated form to enrich content in:
    • Blog posts and infographics
    • Emails, such as a weekly or monthly insight
    • Social media posts
    • Campaigns

This will never contain data or insights or information that can be tracked down to you personally.

We will always use the minimum data required and will process to the minimum extent required.

Legal obligations:

We will also process your personal data where we are under a legal obligation to do so to:

  • Identify you and verify your identity to comply with our Customer Due Diligence and Know-Your-Customer obligations.
  • Prevent and detect fraud, money laundering, other crime, and security issues, and to reduce our business risks.
  • Comply with laws and regulations, as well as any sector-specific guidelines and regulations.

3. Your key rights

Your primary right is the right to stop processing your data (right to object):

  • You have the right to ask us not to process your personal data for marketing purposes by emailing us.
  • You have the right to object to us processing information about you where we do so on the basis of a legitimate interest. If we cannot make that work, it could mean that we may not be able to provide you with the PharmaFlexi App at all.

Your other rights are:

Right of access and data portability:

All data that you have provided us is accessible in the PharmaFlexi App. You can request a copy of all personal data you have provided us through the PharmaFlexi App or via the email-address you have provided us at registration.

Right to rectification:

You can control your data through the PharmaFlexi App. Where you cannot change this data through the PharmaFlexi App, you have the right to ask us to rectify inaccurate or incomplete personal data which we have about you.

Right to erasure:

You have the right to ask us to erase your personal data.

  • Be aware that the partners you have activated may still have data about you. You will need to contact them directly in order for them to delete this data.

4. Where do we store your personal data?

Your data is stored in Bangladesh:

The personal data we collect from you is stored on secure information technology systems located in Bangladesh. For the provision of customer support, or as necessary to troubleshoot the PharmaFlexi App, we may give access to our systems to suppliers outside of Bangladesh. Partners could decide to store your data in other countries or parts of the world than we do. That is not in our control and between you and the partners you connect. We recommend you to carefully read their privacy policies. Upon connection to a partner, the PharmaFlexi App will give you easy access to these privacy policies.

5. Protecting your personal data

  • We are committed to ensuring that your personal data is secure.
  • In order to prevent unauthorised access to or disclosure of it, we have put in place suitable physical, electronic and operational procedures to safeguard and secure the personal data we collect about you.
  • In particular, we protect your personal data by deploying SSL and high standard encryption algorithms.
  • We also ensure that we meet security standards imposed by law that are applicable to the operation of Yolt.
  • We will never ask your password or other security credentials.

Help us protect you:

  • To help us protect your personal data, you agree to comply with our security policies and procedures that we notify to you from time to time. 
  • You also agree to take all reasonable steps to prevent the unauthorised or fraudulent use of your User Login or password, or other security credentials.
  • If you find out or suspect that your PharmaFlexi App's User Login, password, has been lost, stolen, or someone has used it without your permission, you must tell us as soon as possible.

6. Partner platform

We may use your personal data to enable you to use or purchase the products or services of our partners in the Partner Platform if you want to connect with one of our partners. We only share your personal data if you consent to connect a partner.

  • Only after such consent will we disclose or prefill your personal data to those third parties.
  • We won't disclose more than is needed for the products and services of that partner. 

Always read the partner’s terms and conditions and their privacy policy:

  • The use of your data by the partners will be governed by their terms and conditions and their privacy policy – we do not control this.

De-activate a partner:

You can always de-activate a partner:

  • This will stop any data-exchange, but be aware that a partner could retain certain personal data about you that has been exchanged before.
  • If you want a partner to delete your data then you should contact this partner directly.

7. Providers, regulators and law enforcement

Other than what is described above, we will only share your personal data in a very limited way. This will happen either where we need to use services we cannot build ourselves or have a duty or legal obligations to disclose it:

  • Our service providers (including their sub-contractors). This may happen where they help us to run our service or the technology systems that are needed to operate our PharmaFlexi App and services. This includes:
    • Data storage providers to safely and securely store your data.
    • Aggregation service providers, where necessary in order to retrieve Account Information for use in the PharmaFlexi App on your behalf.
    • Identification and verification service providers, to help us adhere to our legal obligations to verify your identity and the information you give us
    • Social Media Platforms via anonymised campaign-IDs so that we can provide relevant content to you on Social Media.
    • Email services e.g. to send you regular updates or communication.
    • Customer relation management to provide you with customer care services.
    • Website and app analytics to provide you with the best experience.
  • Regulators in connection with their duties, such as crime prevention or carrying out regulatory oversight of what we do.
  • Fraud prevention agencies and law enforcement agencies, to prevent and detect fraud, money laundering or other crimes.

8. How long do we keep your data

We are only allowed to keep your personal data for as long as it's still necessary for the purpose we initially required it. If (local) regulations require us to retain it longer or delete it sooner, we will follow these retention periods.
If you delete your PharmaFlexi we will use feasible solutions to make it no longer directly available in our systems, like archiving it. This means that in such case we will no longer process your data.

9. Using computers to make decisions about you

The PharmaFlexi App produces smart insights to empower you. We store information about you into our systems in order to make decisions on what products and services to recommend to you.

10. Our contact details

  • We can be contacted at email@address.com

Complaints to the privacy regulator

You have the right to complain to the privacy regulator in the country in which you reside, where you work, or anywhere where you believe we might have broken data protection rules.

Version: 1 - Published 23rd June 2020, effective 23rd June 2020