SwipeRx Privacy Policy

1. Introduction

1.1 SwipeRx is an online social networking platform for pharmacy professionals, therein including pharmacists, pharmacy assistants (Pharmacy Technicians), pharmacy owners and any other key stakeholders in the pharmaceutical field.  The goal is to help promote access to information and encourage collaboration among pharmacy employees.  In doing so, SwipeRx collects and stores user information securely. 

1.2 By using the SwipeRx application (“Application”), accessing the SwipeRx website (“Site”) or any other application (“Services”) provided by mClinica Pte. Ltd. (“mClinica”), You agree to be bound by this Privacy Policy.  The Application and Site is owned and controlled by mClinica.  If You do not agree to be limited by this Privacy Policy, You are not permitted to use this Application or Site. 

1.3 The term “You” or  User shall include anyone who has registered an account on the Application or Site, or has used the Application or Site.

2. Types of information we collect

2.1 Registration 

SwipeRx is a social and professional network, exclusively for pharmacy professionals.  We collect information necessary to verify that users are pharmacy professionals, including name, location, e-mail, telephone number, education background, pharmacist license number, work experience, professional affiliation, age, date of birth and gender (“Personal Data”).  Users are also encouraged to add their own profile pictures to enhance the overall networking experience.  If You apply to use features related to procuring products through SwipeRx, we also collect additional information for verification purposes, including but not limited to names of personnel in charge, license details, bundled company documents, contact details and others deemed appropriate by mClinica. 

2.2 Profile Information 

Apart from the information provided during registration, Users can add more information about themselves, their experiences, skills, and interests.  This information will improve the way to identify professionals represented on the platform and improve the overall quality of the network. 

2.3 Phonebook and other services synchronized with SwipeRx 

You can use the SwipeRx tool to import contacts via your mobile phonebook, e-mail account or other platforms (“Contacts”), where You store your information.  We will store your information and help You find your contacts already on the SwipeRx platform, as well as invite those who are not.  This will improve your SwipeRx experience.  When You send an invitation to someone in your Contacts to join SwipeRx and to connect with You, that person may have access to your email address or mobile number (for SMS invitations) as it may be displayed on the invitation.  We may also alert invitees on your behalf if they do not promptly accept your invitation.   

Any contact information You synchronize with the SwipeRx platform is governed by this User Agreement and Privacy Policy.  You can delete your information at any time by contacting our Data Protection Officer at the contact details provided below. 

2.4 Customer service 

When You contact our customer service support, we may need to access your account, activity and messages and collect information to understand your questions, respond to them and provide solutions. 

2.5 Using the Services 

When You use the Services, whether through the Application or Site, we collect information about your usage activities – for example – when You click any advertisement, fill in any survey, post or engage in any content, find any content, apply for a job and any other activities. 

2.6 Cookies 

We use cookies and similar technologies to help us get to know You in various tools and provide a better level of security, as well as improve your experience with SwipeRx.

3. How we use your Personal Data

3.1 Consent to the SwipeRx processing information about You 

When You create an account and use the Services, You share Personal Data with us. By providing Personal Data to us, You explicitly and voluntarily accept the terms of our User Agreement, accept and approve the processing and transfer of your Personal Data in accordance with this Privacy Policy.  You can withdraw your approval at any time by deleting your account information or by contacting our Data Protection Officer at the contact details provided below. 

3.2 User communication 

When You initiate communications with any other users on SwipeRx or when You invite people outside the platform, your name, profile picture, e-mail and/or phone number may be shared with any other parties with whom You communicate. 

3.3 Development of customized services and experiences. 

Depending on your Personal Data, we will provide features that improve your experience.  Examples include jobs, events, and any other content tailored to your work experience, location, and education. 

3.4 Marketing messages 

We may send You marketing information about our goods or services including notifying You about our marketing events, initiatives and promotions, sweepstakes, membership schemes, and other prizes and promotions.

4. Sharing information with third parties

4.1 Other members of the SwipeRx network can only see your name, location, work experience, professional affiliation and education.  Your email, telephone number, pharmacist license number, age, date of birth and gender are only available to our team for contact and verification purposes and to employers/managers when You apply for jobs through the platform.  We do not disclose your personal data to anyone, apart from the purpose of contacting You in relation to the SwipeRx Application and Services You use, including applying for jobs on the Application and verifying your CPD exam attempts.  We do not sell Personal Data to any third party without your consent. 

4.2 We may disclose your Personal Data (a) to any third party data processors that we have engaged in performing any of the functions set out in paragraph 3 above, and which may be based within or outside the jurisdiction where the User exists; (b) to any third party service provider partnered with us to facilitate your registration for CPD event and provide You with any other functions of the Application; (c) as part of or in preparation for the sale of mClinica, or as a sale of assets, subsidiaries or divisions; (d) as a result of or in preparation for a change in control of mClinica or any of its affiliates. 

4.3 Any third party to whom we transfer or sell our assets shall have the right to continue using the Personal Data and other data that You provide to us in the manner set out in this Privacy Policy.

5. Access and Correction

5.1 If the User wishes to make (a) an access request to access a copy of the Personal Data we own about the User or information about how we use or disclose the User Personal Data, or (b) a correction request to correct or update the User Personal Data that we hold, You can apply a request in writing or by email to our Data Protection Officer at the contact details provided below. 

5.2 Please note that a reasonable fee may be charged for any access request.  In such case, we will notify You of such fees before processing your request. 

5.3 We will respond to your request as soon as possible.  If we are not able to respond to your request within thirty (30) days upon receipt of your request, we will notify You in writing within thirty (30) days of when we will be able to respond to your request.  If we are unable to provide You with Personal Data or to make corrections as You requested, we will generally tell You the reasons why we cannot do so (unless we are not required to do so under applicable laws of data protection). 

6. Accuracy and Retention

6.1 To ensure that User Personal Data is current, complete, and accurate, please update mClinica if there is any change of User Personal Data by informing our Data Protection Officer in writing or by email at the contact details provided below. 

6.2 We may retain User Personal Data for as long as necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable law. 

6.3 We will stop retaining User Personal Data, or delete that means by which such data can be associated with a, particular User, as soon as it is reasonable to assume that such retention no longer serves the purposes of the Personal Data collection, and is no longer necessary for legal or business purposes. 

7. Transfers

7.1 Personal Data that we collect from Users may be transferred out of the jurisdiction in which the User is based to be hosted on our third-party data processing servers located in Singapore.  In the event of any transfer of Personal Data outside the jurisdiction, we will take steps to ensure that your Personal Data continue receiving a standard of protection that shall at least be comparable with that provided under prevailing regulations on personal data protection in Indonesia.

8. Change and security

8.1 Changes in this Privacy Policy 

We may change this Privacy Policy from time to time.  If there is any change in the way we treat your Personal Data or in the Privacy Policy requiring your consent under applicable regulations, we will provide You with email notification within 7 days prior to the change.  If You continue using the Application, Site and Services upon effective commencement of the changes in the Privacy Policy, You are deemed to have read, acknowledged, and agreed to the updated Privacy Policy. 

8.2 Security 

We have established and implemented security practices to protect your Personal Data from any unauthorized access, collection, use, dissemination, duplication, modification, deletion or any risks similar thereto, equivalent to industrial standards, therein including implementation of authentication restrictions and Open SSL encryption on API, among others.  Access to your data is password protected.  We regularly monitor and keep our security standards up to date.  However, we do not guarantee the security of any information You send to us and we strongly advise against sharing any confidential information through our platform, messages and group discussion features.  We will only disclose information internally and to agents and data processors as authorized third parties.

9. Data Breach and Notification

9.1 In the event of any data breach, we will notify You as soon as practically possible, by first ensuring that the use of the personal data is harmful to You, except in conditions such as 1) the necessary corrective action has been taken so that any occurring data breach does not cause any significant harm, 2) appropriate technological measures have been applied to personal data before a breach occurs resulting in the personal data being inaccessible 3) restrictions from law enforcement agencies related to any ongoing investigation or applicable relief.  In the notification provided, we will provide relevant details regarding the data breach, therein including applicable policies related to breach management and data recovery. 

10. Governing Language

This Privacy Policy is prepared in Indonesian language and English. If there is any inconsistency between the two versions, the Indonesian language version prevails.

11. Data Protection Officer

11.1 Users can contact mClinica Data Protection officer in case You have any questions or feedback regarding our Personal Data protection policies and procedures, or if You wish to make any request, in the following manners:

Data Protection Officer
Email : [email protected] with Privacy Policy in your email subject row

Last updated: December 4, 2023