Effective Date: 22 August 2024

VetScript Pty Ltd (“VS”, “we”, “us” or “our”) is Vet Prescription Exchange Service integrated into Practice Management Software(s) (PiMS) for veterinary practices and clinics which assists in the management of prescriptions, simplification of workflow, retention of revenue and protection of prescription data (VPES).

A Veterinary Practice means a vet practice who uses the VPES or who expresses interest in the VPES either to VS or a VS Third Party Provider, and includes the veterinarians of the Veterinary Practice.

A Pharmacy means a pharmacy that is capable of interacting with the VPES via the Pharmacy Dispensing Software Partner.

A Pet Owner means the human owner of the pet who engages the Veterinary Practice for veterinary services which includes the requirement for a prescription medicine for the pet.

You means a Veterinary Practice, a Pharmacy and a Pet Owner.

VS Third Party Providers includes our partnered Practice Management Software(s) (PiMS), the Customer Relationship Manager (CRM) used by our PiMS partners, our Software Support Partner and our Pharmacy Dispensing Software Partner. Our VS Third Party Providers may change from time to time. For a current list and further information about our VS Third Party Providers, please contact us.

VS Website means our website: https://vetscript.io/.

We respect your privacy and are committed to protecting it through our compliance with this privacy policy (Policy). This Policy describes the types of information we may collect from you or that you may provide via the VPES or the VS Website, and our practices for collecting, using, maintaining, protecting, and disclosing that information. It also describes the choices available to you regarding our use of your information and how you can access and update it.

This information is handled subject to the Privacy Act 1988 (Cth) (“Privacy Act”) and Health Records Act 2001 (Vic) and the equivalent legislation in the relevant Australian states and territories (“Health Records Act”). This Policy is published in accordance with Australian Privacy Principles (APPs) in Schedule 1 of the Privacy Act.

This Policy is a legally binding agreement between you and VS. If you are entering into this agreement on behalf of a person, business or other legal entity, you represent that you have the authority to bind such person or entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to such person or entity.

If you do not agree with the terms of this agreement, you must not accept this agreement and must not access and use, or consent to the use of, the VPES or the VS Website. By allowing for the integration of and using the VPES, or consenting (even if implicitly) to your Veterinary Practice using the VPES, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy.

We only collect, use, and disclose personal information where this is permitted by the Privacy Act and for the purposes outlined in this Policy.

Specific information about the personal information we collect, use, and disclose to carry out specific activities is outlined below.

Please read this Policy carefully in order to understand how your personal information may be collected, held, used, or otherwise processed by us.

VS reserves the right to make changes or updates to this Policy from time to time. If this happens, we will update this Policy on the VS Website (https://vetscript.io/privacy-policy/).

---

1. What is ‘personal information’?

Personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

2. Collecting personal information

The types of personal information we may collect about you include:

If you are a Pet Owner:

• Identity data (such as name, title, etc.)
• Contact data (such as email address, phone number, address, etc.)

If you are a Veterinary Practice:

• Practice information (such as practice name, Australian Business Number (ABN), phone number, email address and practice address)
• Head veterinarian personal data (such as name, vet registration number, title)
• Head veterinarian contact data (such as email address, phone number, etc.)
• Practice owner/director personal data (such as name and title)
• Practice owner/director contact data (such as email address, phone number, etc.)
• Practice manager personal data (such as name and title)
• Practice manager contact data (such as email address, phone number, etc.)
• Signature of the practice owner/director and/or practice manager
• Technical and Usage Data: when you access the VS Website, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of the VS Website (including through the use of internet cookies), and communications with the VS Website.

If you are a Pharmacy:

Technical and Usage Data: when you access the VS Website, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of the VS Website (including through the use of internet cookies), and communications with the VS Website.

Pharmacy information (such as pharmacy name, pharmacy approval number, Australian Business Number (ABN)/Australian Company Number (ACN), phone number, email address and pharmacy address)

Nominated pharmacist personal data (such as name, title, signature, etc.)

Nominated pharmacist contact data (such as email address, phone number, etc.)

Pharmacy owner/decision maker personal data (such as name, title, signature, etc.)

Pharmacy owner/decision maker contact data (such as email address, phone number, etc.)

Accounts contact personal data (such as name, title, etc.)

Accounts contact data (such as email address, phone number, etc.)

Information to facilitate direct debit payments (including bank account name, BSB and account number through our third-party payment processor)

Technical and Usage Data: when you access the VS Website, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of the VS Website (including through the use of internet cookies), and communications with the VS Website.

3. How we collect personal information

We collect personal information from/via/due to:

If you are a Pet Owner:

• When a vet or pharmacy creates a prescription record within VPES, which includes the Pet Owner’s contact and personal data.

If you are a Veterinary Practice:

• Via our partnered PiMS and related CRM when a Veterinary Practice fills out the online form to register interest in the VPES.
• From the Veterinary Practice directly when interest in the VPES is provided to VS.
• From the Veterinary Practice directly upon completing and returning the VetScript Enrolment Form and Clinic Integration Enrolment Form via DocuSign and any other contract or agreement with us.
• From the Veterinary Practice directly during site visits, telephone calls, emails, and other forms of contact.
• Via use of the VPES.
• When you provide your personal information on the VS Website.

If you are a Pharmacy:

• Via our Pharmacy Dispense Software Partner, who deems the Pharmacy suitable to participate within the VS network.
• From the Pharmacy directly upon entering into a pharmacy license agreement with VS for the VPES.
• From the Pharmacy directly during site visits, telephone calls, emails, and other forms of contact.
• Via use of the VPES.

If you are uncertain about what information is mandatory to provide, you are welcome to contact us at support@vetscript.io.

4. What is ‘sensitive’ information’?

Sensitive information is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information, or biometric information.

5. Collecting sensitive information

We do not ordinarily collect sensitive information from or about you, but we may collect sensitive information about you if you provide it to us.

6. Why we collect personal information

We collect personal information for reasons including:

• Contacting Veterinary Practices and Pharmacies who are interested or suitable for the VPES.
• Communicating with Veterinary Practices and Pharmacies.
• Onboarding Veterinary Practices and Pharmacies.
• Marketing and promotion of the VPES.
• For billing and payment processing purposes.
• To provide and facilitate use of the VPES.
• To better and improve the VPES.
• Prescription formation.
• Data analytics.
• Facilitating shipping and delivery of prescribed medications.

7. Disclosure of your personal information

We only disclose your personal information for the purposes that you provide it to us, to meet our obligations to VS Third Party Providers, or to comply with our legal obligations.

We disclose information to facilitate script creation, script dispensing, any ancillary and related process to achieve the VPES, billing, shipping, marketing, data analytics, and to onboard users to the VPES and provide support.

The VPES facilitates the sharing of information between Veterinary Practices and Pharmacies. Information is shared via the creation and sending of prescriptions, which includes Pet Owner information and Veterinary Practice information, including the name of the specific vet. Further, dispensed medications are delivered to a nominated address (e.g., the Veterinary Practice or the Pet Owner’s address). We may also share contact details of Veterinary Practices with Pharmacies to assist in the establishment of business relationships.

To facilitate the full suite of services, the VPES discloses personal information between these parties.

The VPES is supported by VS Third Party Providers, to whom we disclose personal information. We disclose personal information to VS Third Party Providers to assist us and them in providing the VPES, offering and providing support to you, and to meet our reporting obligations to VS Third Party Providers.

VS only discloses the information as necessary to achieve the abovementioned purposes.

VS Third Party Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. VS Third Party Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes.

Your personal information may be required or authorized to be disclosed when it is:

• To you.
• With your consent.
• Necessary to lessen or prevent a serious threat to a patient’s life, health or safety or public health or safety, or if it is impracticable to obtain a patient’s consent.
• Required under any relevant law or required to inform health agencies or report to veterinary boards.

In each case, we will only disclose the minimal amount of information necessary for the relevant purpose.

Payment Processing

Where payment account information is required, it will be used solely for processing payments. We use a third-party payment processor to assist us in processing payment information securely.

We will share payment data with the payment processor only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.

Please note that the payment processor may collect some personal information from you, which allows them to process your payments (e.g., your email address, address, bank account name, number, and BSB) and handle all the steps in the payment process through their systems, including data collection and data processing.

The payment processor’s use of your personal information is governed by their respective privacy policies, which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.

8. Storage and security of personal information

The VPES has various technical security controls such as:

• Application programming interface (API) keys (software vendor integration).
• Multifactor Authentication (end-user logins).
• Encryption in transit (Transactional).
• Encryption at rest (Transactional).
• Site-specific certificates (Veterinary Practice/Pharmacy authentication).

The VPES’s administration portal is only accessible by VS employees. The administrative portal is not available to third parties, with account creation only performed internally. Each VS Employee must have a strong password with multifactor authentication enabled by default.

Other than the administrative portal, VS acts as a middleware software and is largely transparent to Veterinary Practices and Pharmacies. There is no login interface for Veterinary Practices and Pharmacies.

VS does not handle any electronically stored files. The prescription transactions facilitated by the VPES are stored in a database which is encrypted at rest. All data transmitted to and from VS is encrypted at rest in line with Australian Cyber Security Centre (ACSC) standards.

We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of personal information in our control and custody. However, no data transmission over the internet or wireless network can be guaranteed.

Therefore, while we strive to protect your personal information, you acknowledge that:

1. There are security and privacy limitations of the internet which are beyond our control.
2. The security, integrity, and privacy of any and all information and data exchanged between you and the VPES cannot be guaranteed.
3. Any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

As the security of personal information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.

Data breach

In the event we become aware that the security of the VPES or VS Website has been compromised or your personal information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including:

• Investigation and reporting.
• Notification to and cooperation with law enforcement authorities.

In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to you as a result of the breach or if notice is otherwise required by law.

When we do, we may notify you via:

• Email.
• Phone.
• Letter.

9. Collecting through the VS Website

We will collect your personal information if you provide it when using the VS Website. We will use this information for the purpose for which you provided it.

Automatic collection of information

When you access the VS Website or the VPES, our servers automatically record information that your device sends. This data may include:

• Your device’s IP address and location.
• Device name and version.
• Operating system type and version.
• Language preferences.
• Information you search for in the VPES or VS Website.
• Access times and dates.
• Other statistics.

Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage of the VPES and VS Website.

This statistical information is not otherwise aggregated in such a way that would identify you.

Website analytics and cookies

The VS Website may use third-party analytics tools that use:

• Cookies
• Web beacons
• Other similar information-gathering technologies

These tools collect standard internet activity and usage information to compile statistical reports on user activity, such as:

• How often users visit the VS Website.
• What pages users visit and for how long.

We use this information to monitor performance and improve the VS Website and VPES.

We do not use third-party analytics tools to:

• Track or collect any personally identifiable information of our users.
• Associate any information gathered from the statistical reports with any individual user.

The VS Website uses third-party tools such as Google Analytics to help improve the user experience.

Google Analytics Data Collection:

We may collect the following data through Google Analytics:

• Your device’s IP address.
• Type of device.
• Browser used to visit the website.
• Geographic location.
• Search terms.
• Pages visited.
• Date and time when website pages were accessed.

Google Analytics collects information using cookies. Cookies are small data files transferred onto computers or devices by websites.

We use cookies on our platform for:

• Record-keeping purposes.
• Enhancing the platform’s functionalities.

VS may collect other user interaction information through cookies.

Managing Cookies:

Most browsers allow you to choose whether or not to accept cookies.

You can find further information on how to manage or disable cookies in common browsers below:

• Google Chrome
• Internet Explorer
• Firefox
• Safari

If you disable all cookies in your browser, certain sections of the VS Website may not work.

10. Social Networking and Marketing

We may use social networking services such as Twitter, Facebook, LinkedIn, and YouTube to communicate with the public about the VPES and VS Website.

When you communicate with us using these social media platforms, we may collect your personal information if you provide it, but we only use it to help us to communicate with you.

The social networking service may also handle your information for its own purposes. These services have their own privacy policies.

You can access the privacy policies for:

• Facebook
• Instagram (Meta)
• LinkedIn
• Twitter
• YouTube (a Google company)

Advertisements

We may display online advertisements and may share aggregated and non-identifying information about you that we or our advertisers collect through your use of the VPES and VS Website.

• We do not share personally identifiable information about individual users with advertisers.
• In some instances, we may use aggregated and non-identifying information to deliver tailored advertisements to the intended audience.

The VS Website may include social media features, such as:

• Facebook and Twitter buttons.
• Share This buttons.

These Social Media Features may collect:

• Your IP address.
• What page you are visiting on the VS Website.
• Set a cookie to enable Social Media Features to function properly.

Social Media Features are hosted either by their respective providers or directly on our Platform.

Your interactions with these Social Media Features are governed by the privacy policy of their respective providers.

Email marketing

You agree to receive application message, email, and SMS marketing from us or from a third-party marketing service provider engaged by us.

We offer electronic newsletters, which you may voluntarily subscribe to at any time.

We are committed to keeping your email address confidential and will not disclose your email address to any third parties except as necessary for the purpose of utilising a third-party provider to send such news and marketing emails.

We will maintain the information sent via email in accordance with applicable laws and regulations.

In compliance with the Spam Act 2003 (Cth), all emails sent from us will:

• Clearly state who the email is from.
• Provide clear contact information on how to reach the sender.
• Include unsubscribe instructions so you can opt out of newsletters or marketing emails.

To stop receiving newsletters or marketing emails, you can:

• Follow the unsubscribe instructions included in the emails.
• Contact us at support@vetscript.io.

However, you will continue to receive essential transactional emails.

11. Disclosure of personal information overseas

• Web traffic information is disclosed to Google Analytics when you visit part of the VS Website.
• Google stores information across multiple countries.

When you communicate with us through a social network service such as Facebook or Twitter, the social network provider and its partners may collect and hold your personal information overseas.

Other than via the above channels, VS will not disclose personal information to anyone outside Australia without need and without your consent.

12. Accessing and correcting your personal information

Under the Privacy Act and other legislation, you have a right to access the personal information we hold about you.

Please contact us for assistance via the details set out in Part 15 below.

If you believe the personal information we hold about you is not accurate, complete, or up to date, please contact us as soon as possible for assistance.

You may also be able to delete certain information we collect about you.

To request deletion of your information, contact us at support@vetscript.io.

13. Retention of information

Unless a longer retention period is required or permitted by law, we will retain and use your personal information for the period necessary to:

• Comply with our legal obligations.
• Enforce our agreements.
• Resolve disputes.

Once the retention period required or permitted by law expires, your information held by us may be deleted.

Therefore, the following rights cannot be enforced after the expiration of the retention period:

• Right to access.
• Right to erasure.
• Right to rectification.
• Right to data portability.

14. How to make a complaint

If you wish to complain to us about how we have handled your personal information please write to us by sending your enquiry or complaint via email to support@vetscript.io. Please address your correspondence to ‘The Privacy Officer’. If you need help lodging a complaint, you can contact us – see ‘How to contact us’ at part 15 below.

If we receive a complaint from you about how we have handled your personal information we will determine what, if any, action we should take to resolve the complaint. We will tell you promptly that we have received your complaint and then respond to the complaint within 30 days.

If you are dissatisfied with the outcome of the complaint or the way in which the complaint was handled, you may contact the Office of the Australian Information Commissioner for advice about your complaint.

15. Contact us

If you have any questions regarding the information we may hold about you, if you wish to exercise your rights, or if you have any other questions, concerns or complaints regarding this Policy, please contact us at:

Telephone: 1300 777 838 , 9am – 5pm (AEST/AEDT), Monday – Friday
Email: support@vetscript.io

Assisted contact:

• If you need an interpreter, call TIS National on 131 450
• For hearing or speech assistance, contact the National Relay Service or call 1300 555 727.

16. Changes and amendments

We reserve the right to modify this Policy at any time at our discretion. When we do, we will amend the Policy as published on the website which shall have a revised ‘last reviewed’ date at the bottom of the Policy. We may also provide notice to you in other ways at our discretion, such as via notification posted on the VS Website, via email or via other contact information you have provided.

An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the VPES and VS Website after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your personal information in a manner materially different than what was stated at the time your information was collected.

17. Acceptance of this policy

You acknowledge that you have read and agree to the terms of this Policy. By accessing and using the VS Website, the VPES and/or by submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorised to access or use the VS Website or the VPES.

Date of last review / version

This document was last updated on February 20, 2025.