Privacy Policy

How Pharmacy HQ collects, uses, and protects your information.

Last updated: 17 October 2026  ·  Effective: 31 October 2026

In plain English: We collect the minimum data needed to run your pharmacy operations dashboard. We don't sell your data, we don't share it with advertisers, and your operational data belongs to you. This policy explains the details.

Contents

  1. Who we are
  2. What information we collect
  3. How we use your information
  4. Who we share information with
  5. AI features and Anthropic
  6. PreCheck, Webster pack AI verification
  7. Data storage and security
  8. How long we keep your data
  9. Your privacy rights (Australian Privacy Act)
  10. Cookies, browser storage and tracking
  11. Pharmacy and health-adjacent data
  12. Our mobile apps
  13. Children's privacy
  14. Changes to this policy
  15. Contact us

1. Who we are

Pharmacy HQ is a software-as-a-service (SaaS) product providing staff operations dashboards for Australian pharmacies. It is operated by Pharmacy HQ Pty Ltd (ACN 698 203 164 · ABN 86 698 203 164), an Australian company with registered office at C/- Perrier Ryan Business Advisors, Level 1, 30 Lisburn Street, East Brisbane QLD 4169.

In this policy, "Pharmacy HQ", "we", "us" and "our" refer to Pharmacy HQ Pty Ltd. "You" refers to the pharmacy owner, manager, or staff member using our service.

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

2. What information we collect

Account information

When you create a Pharmacy HQ account, we collect:

Operational data you enter

All data entered by you or your staff into the application is stored under your pharmacy's account and includes:

Important: Pharmacy HQ stores both operational data (staff records, tasks, diary entries) AND, when you enable the relevant features, patient-adjacent operational data (Webster patient profiles including Medicare/DVA/NDIS, Care Transfer records, Staged Supply dispensing events, vaccination claim records). All such data is stored under your pharmacy's account with strict access controls. We are not a regulated health records platform; the dispensing system at your pharmacy remains the system of record for full clinical medication history. See Section 9 below for the full list of patient-adjacent data categories.

Sensitive information (APP 3.3). Where the pharmacy chooses to record a patient's Aboriginal and/or Torres Strait Islander identification (used to confirm IDAA, Indigenous Dose Administration Aid, program eligibility), that information is "sensitive information" under the Australian Privacy Principles. The pharmacy is the APP entity collecting it; Pharmacy HQ acts as the data processor on the pharmacy's behalf. Pharmacies must obtain the patient's consent before recording this field and may only use it for the specific purpose of confirming IDAA program eligibility. Pharmacy HQ enforces this by gating the field behind an explicit consent prompt at the Webster enrolment form. Concession status and living-setting metadata are not classified as sensitive information under the APPs but are still treated with the same access controls as other patient-adjacent data.

Information from services your pharmacy connects

Technical data collected automatically

When you use our application, we or our infrastructure providers may automatically collect:

Data typeCollected byPurpose
Auth tokens & session dataFirebase Authentication (Google)Keeping you signed in securely
Pharmacy data (patients, staff, tasks and other records)Cloud Firestore (Google), SydneyStoring your pharmacy's data and keeping it in sync across devices
A limited set of recordsFirebase Realtime Database (Google), United StatesBeing moved to Sydney; Section 5 lists what it holds
Payment & billing dataStripe, Inc.Processing subscription payments
Email delivery logsResend, Inc.Welcome, billing, and claim-nag emails

3. How we use your information

We use the information we collect for the following purposes:

We will never sell your data to third parties, use it to serve you advertisements, or share it with anyone who is not listed in Section 4 of this policy.

4. Who we share information with

We share data only with the following trusted third-party providers, and only to the extent necessary to provide the service:

ProviderCountryPurposeTheir Privacy Policy
Google Firebase Australia (Sydney, australia-southeast1) for your pharmacy's data in Cloud Firestore, file uploads, backups and our cloud functions. USA for the Realtime Database described in Section 5 and for Google's global services such as Firebase Authentication. Authentication, Cloud Firestore database, file storage, backups, cloud functions firebase.google.com/support/privacy
Stripe, Inc. USA Payment processing and subscription management stripe.com/au/privacy
Resend, Inc. United States, with emails sent from Japan (Tokyo) Transactional email delivery (welcome, password reset, billing alerts, claim-nag reminders) resend.com/legal/privacy-policy
Cloudflare, Inc. USA (global edge) DNS hosting, Email Routing (inbound automated reports e.g. fridge temperature logs), Workers (transforming inbound emails into structured records), and Turnstile, the bot check on a pharmacy's public online-booking page. Turnstile sees the visitor's IP address and browser characteristics to decide whether the request looks automated; it does not receive anything typed into the booking form. cloudflare.com/privacypolicy
Anthropic PBC USA AI model (Claude API) for the AI features in Section 4a: Help Chat, Policy Chat, Workflow Chat, AI Scribe, incident auto-tagging, the QSPP writing tools, invoice reading and reading emailed scripts. PreCheck does not use this service. Anthropic does not store or train on prompts under its commercial terms. anthropic.com/legal/privacy
Mobile Message (ABN 56 669 495 916) Australia (Sydney). Some outgoing message content is checked by OpenAI in the USA, see below Our main text message provider: outbound and inbound SMS (delivery and collection notifications, holiday-hours cohort SMS, sick-call alerts to staff, pre-shift reminders). Each text includes the recipient's phone number and the message. To prevent scams, Mobile Message has some outgoing message content checked by OpenAI in the United States; Mobile Message has told us in writing that this content is used only for that check and never to train AI models. Mobile Message keeps message records for the life of Pharmacy HQ's account with it, and deletes them when we ask, except where the law requires it to keep them; deleted records leave its backups within about six months. mobilemessage.com.au/trust
Twilio Inc. USA (global) Backup text message provider, also used for replies in text conversations that began on it. Outbound and inbound SMS (delivery and collection notifications, holiday-hours cohort SMS, sick-call alerts to staff, pre-shift reminders). Sick-call alerts are sent only if the pharmacy's Owner switches them on. They name the staff member and the shift, and never include the reason for the absence. If our main provider refuses a text or is unavailable, that text is sent through Twilio instead. Twilio processes and stores each message in the United States. twilio.com/en-us/legal/privacy
Pharmacy Programs Administrator (PPA) , per-claim Australia When you submit a MedsCheck, NIPVIP, CVCP, DAA, or Staged Supply claim, patient identifiers (name, DOB, Medicare/DVA), vaccine batch/lot, and service particulars are sent to PPA's API under your existing Service Provider Agreement ppaonline.com.au/privacy
Xero , when connected New Zealand If you connect Xero in Pharmacy Settings → Integrations → Xero Payroll, approved timesheet data + staff identity is pushed to Xero on demand. Pharmacy HQ does not pull data from Xero. xero.com/au/legal/privacy
Google Maps Platform , when enabled USA (global) If you enable Deliveries route optimisation, delivery addresses are geocoded + routed via Google Maps APIs. Address strings only, no patient names. policies.google.com/privacy

Authoritative sub-processor list: for the current authoritative list of every data sub-processor + their role + jurisdiction, see pharmacyhq.com.au/sub-processors. That page is updated whenever a sub-processor is added, removed, or changes role, it is the single source of truth and takes precedence over any listing in this document.

All of these providers are bound by their terms with us to handle your data only to provide their service. Some of them process data outside Australia, as the Country column shows. Section 5 sets out where your data is stored and what is processed overseas.

We may also disclose your information if required to do so by Australian law (for example, in response to a court order or regulatory request).

4a. AI features and Anthropic

Pharmacy HQ has the AI features listed below. All of them except PreCheck use Anthropic's Claude model through Anthropic's own service in the United States. The list says what each feature sends. Each AI feature carries a small "AI" label in the app.

Not everything below is switched on yet. PreCheck, AI Scribe and AI reading of emailed scripts are still in testing and are not enabled for live pharmacies. Each is switched on only after that testing completes, and this section applies to each from the moment it is enabled. When they are enabled, PreCheck and AI Scribe stay off for each pharmacy until its Owner turns them on in Pharmacy settings → AI features, because they handle pack photos and consultation notes. The other AI features are on unless the Owner turns AI off for the pharmacy.

What is sent to Anthropic

For every feature above except PreCheck, what is sent goes to Anthropic's API in the United States. For the Help, Policy and Workflow chats, that is the text of your question and the information the assistant needs to answer it, which may include patient names, prescription details or other pharmacy records. PreCheck does not use Anthropic's US API: see Section 4b.

Dictation

The MedsCheck consultation notes have a Dictate button. Dictation uses the speech recognition built into your web browser; it is not one of Pharmacy HQ's AI features and it does not use Anthropic. In Google Chrome, the browser sends your voice to Google to turn it into text, under Google's own terms for Chrome. Other browsers may use their own maker's speech service in the same way. Pharmacy HQ receives only the text, never the audio. The pharmacy AI switch does not turn dictation off. If you do not want your voice to leave the computer, type the notes instead.

What Anthropic does with it

Under Anthropic's commercial terms in effect at the date of this policy, requests and responses are not used for model training and are not retained beyond the time required to deliver the response (subject to Anthropic's standard logging for abuse prevention).

What we log on our side

We log metadata only, timestamp, surface (help / policy / workflow / pre-check), tokens consumed, latency. We do not log the prompt or the response text on our side. This is a deliberate PHI-hygiene choice; the trade-off is we can't audit the content of historical AI queries.

How to opt out

The pharmacy owner can disable AI features for the entire pharmacy in Pharmacy settings → AI features. Once disabled, no Anthropic API calls occur from your pharmacy's account: every AI surface, the Help, Policy and Workflow chats, the MedsCheck AI scribe, invoice reading, incident auto-tagging, the QSPP writing tools, and PreCheck, refuses instead of calling out. The switch is enforced on our servers, not in the browser, so it holds regardless of which device or app version a staff member is using. Only the owner can change it; a manager cannot. Prescriptions emailed to your script inbox continue to arrive while AI is off, they are simply filed without the patient and prescriber details being read out of them. PreCheck is additionally opt-in per patient (Section 4b): patient consent and this pharmacy-level switch must both allow it.

4b. PreCheck, Webster pack AI verification

PreCheck is an assistive workflow tool that captures an end-of-pack photograph of a Webster (dose administration aid) pack and runs AI image analysis to count the pills it can see in each cell and show the pharmacist where a count differs from the expected count. It is intended to help the pharmacist check a packed pack; it does not decide whether a pack is correct. The pharmacist reviews every result and is solely responsible for verifying the pack before it leaves the pharmacy.

Patient consent (per patient, opt-in)

PreCheck is gated on per-patient consent. The pharmacist obtains the patient's documented consent at Webster enrolment and records it on the patient's Webster profile inside Pharmacy HQ (a structured field: granted, at, by, with a withdrawal field if consent is later revoked). PreCheck capture refuses to upload a photo for a patient whose consent is not granted. Consent is patient-level (not pharmacy-level) and is withdrawable at any time via Pharmacy Settings or by request to the pharmacy.

What is sent, and what is NOT sent

What we send to the AI provider: the cropped image of the pack grid only (the rectangle inside the violet outline shown on the camera preview), plus the expected pill count for each slot and, depending on the AI model used, the name of each expected medicine. The image is cropped client-side using a fixed bounding rectangle before it is uploaded to our servers; everything outside the violet outline is discarded before the image data exists.

What we do NOT send: the patient's name, date of birth, Medicare number, AHPRA number, or any other personal identifier. There is no patient ID, no store ID, and no timestamp in the AI payload that could correlate the image with a patient. We additionally run a server-side OCR redaction check on the cropped image (Google Cloud Vision textDetection) before any AI call; if the OCR detects identifier-shaped text (patient name, DOB pattern, Medicare pattern, or AHPRA pattern) we BLOCK the AI call and prompt the pharmacy staff member to reframe and re-capture.

Where the AI runs

PreCheck sends the cropped pack photo to two services, one after the other.

We do not send either step the patient's name, date of birth, Medicare number, or any patient or pharmacy ID as data. If the text check reads the patient's name, date of birth or a Medicare number in the photo, it stops the photo before the pill count.

Retention

On Vertex AI, request logging is turned off for the PreCheck call (header: X-Vertex-AI-Logging-Off: true). Before PreCheck is enabled for any live pharmacy, this section will say whether the chosen model's provider keeps or trains on the photo.

Pharmacy HQ retains the cropped photograph in your pharmacy's storage bucket alongside the AI result for the audit trail. Photographs are deleted in line with our standard retention schedule (Section 6) or earlier on request.

Audit trail and pharmacy attestation

Every PreCheck capture records a structured privacy field, consent state at capture time, crop bounds applied, OCR preflight result, AI provider, AI region, and retention policy. Pharmacy owners can generate a Privacy Audit Pack (PDF) from the PreCheck tab covering the last 30 days of activity, suitable for OAIC, AHPRA, or insurer enquiries.

How to opt out

Individual patients can withdraw consent at any time by asking their pharmacy to un-tick the PreCheck consent on their Webster profile; subsequent captures for that patient are blocked. PreCheck is off for each pharmacy until its Owner turns it on in Pharmacy settings → AI features, and the Owner can turn it off again there at any time. Turning off AI features for the whole pharmacy also stops PreCheck.

Privacy Impact Assessment

We keep a Privacy Impact Assessment for PreCheck, covering personal information flows, the risk register, mitigations, and the Australian Privacy Principles compliance map. It is updated before PreCheck is enabled for live pharmacies. A pharmacy can ask for a copy at privacy@pharmacyhq.com.au.

5. Data storage and security

Your pharmacy's data, including patient and staff records, is stored in Google Cloud Firestore in the australia-southeast1 (Sydney) region, and our cloud functions run in the same region. File uploads are stored in Firebase Storage in Sydney. Backups of the database are kept in Sydney: daily and weekly backups are kept for 14 weeks, and the database can also be restored to any point in the last 7 days. Mentions of staff (who was mentioned, the sender's name, a short title and up to 400 characters of the message, post, note or task they were made in; a mention on a special order or Webster patient includes the patient's name) are stored in Cloud Firestore in Sydney.

Data still held in the USA. Some of your data is still written to the Firebase Realtime Database, which is hosted in the United States. It covers:

Older copies may also remain there until they are moved or deleted. These include copies, written before 28 September 2026, of merged patient records, which can include a patient's name, date of birth, address and phone number, and of patient requests sent by text reply (the phone number, name and message). They also include copies, written before 19 October 2026, of mentions of staff (who was mentioned, the sender's name, a short title and up to 400 characters of the message, post, note or task they were made in; a mention on a special order or Webster patient includes the patient's name) and a record of who sent each one, and prescription emails that reached your pharmacy's script inbox up to 18 October 2026 (the sender, the subject, the text of the email and of any attached PDF, and the details read from it), which are deleted automatically 30 days after they arrived. We are moving the remaining data to Australia.

Processed outside Australia. Besides the data above, these services process data outside Australia: sign-in accounts (Firebase Authentication, a Google global service); push notifications to staff devices (Firebase Cloud Messaging, a Google global service); emails sent through Resend (United States, with emails sent from Japan (Tokyo), Section 4); the AI features that use Anthropic in the United States (Section 4a); the PreCheck text check by Google Cloud Vision (Section 4b); text messages sent through Twilio in the United States, and the OpenAI scam check used by Mobile Message (Section 4); and the other providers in Section 4 whose country is not Australia.

All data is protected by:

Edge security and inbound mail processing. DNS for pharmacyhq.com.au is hosted on Cloudflare; inbound automated emails (e.g. fridge temperature logs from Clever Logger) are routed through Cloudflare Email Routing and processed by a Cloudflare Worker before being forwarded to our Cloud Functions for ingestion. Cloudflare may temporarily process the email contents in transit; we do not retain Cloudflare's processing logs beyond what their standard logging provides.

While we take reasonable technical measures to protect your data, no internet transmission or electronic storage method is 100% secure. If you become aware of any security vulnerability, please contact us immediately at security@pharmacyhq.com.au.

6. How long we keep your data

You can request earlier deletion of your data at any time by contacting privacy@pharmacyhq.com.au. Billing records may be retained longer if required by law.

7. Your privacy rights (Australian Privacy Act)

Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, you have the following rights:

Right to access your data

You can request a copy of the personal information we hold about you. We will provide this within 30 days of your request. Your operational data is accessible directly through the application at any time.

Right to correction

If any information we hold about you is inaccurate or out of date, you can correct it yourself within the application or ask us to correct it.

Right to deletion

You can request that we delete your account and associated data. Some data may be retained where required by law (e.g. financial records).

Right to complain

If you believe we have handled your personal information in breach of the Privacy Act, you can lodge a complaint with us at privacy@pharmacyhq.com.au. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or on 1300 363 992.

To exercise any of these rights, email privacy@pharmacyhq.com.au. We will respond within 30 days and may need to verify your identity before acting on your request.

8. Cookies, browser storage and tracking

Pharmacy HQ is a single-page web application. We use the following minimal cookies and browser storage:

We do not use advertising cookies, third-party tracking pixels, or social media widgets. The landing page (pharmacyhq.com.au) does not use Google Analytics or any equivalent analytics service that tracks individuals across sites.

9. Pharmacy and health-adjacent data

Pharmacy HQ is primarily a workflow and operations dashboard. We are not a clinical management system, regulated health records platform, or dispensing software. However, several features that you (the pharmacy) can optionally enable do require us to store patient-adjacent operational data.

What we may store, when your pharmacy uses the relevant feature:

What we still do not store:

All patient-adjacent data is gated by Firebase Security Rules so that one pharmacy cannot read another pharmacy's records. Per-feature sensitivity controls (e.g. the Staged Supply path is admin-SDK-write-only, every write goes through an authenticated Cloud Function with an audit log) give an extra layer for the most sensitive paths.

Pharmacy owners remain responsible for ensuring their use of the application complies with applicable pharmacy board and privacy regulations. We provide the platform; you remain the data controller for patient information under the Privacy Act.

If you have specific compliance questions for your pharmacy, we recommend seeking independent legal advice or contacting the Pharmacy Guild of Australia.

9a. Our mobile apps

We publish two iOS and Android apps. They are separate apps for separate audiences, and they collect different things. Everything in the rest of this policy applies to both; this section covers what is specific to a phone.

PHQ Team, the staff app

PHQ Team is for people who work at a pharmacy that uses Pharmacy HQ. You sign in with an account your pharmacy gives you; you cannot create one yourself. In addition to the account and operational data described in section 2, the app may collect:

Pharmacy HQ, the patient app

The patient app is for customers of a pharmacy that uses Pharmacy HQ. Alongside your account details it may hold your prescription and medication information, your Individual Healthcare Identifier, the pharmacy you are linked to, a record of the device you signed in on, and a push notification token.

Payments for physical goods are handled by Stripe. We never see or store your full card number.

Face ID, Touch ID and your PIN

Both apps can lock behind a biometric check or a PIN. Biometric data never leaves your device and is never sent to us, the device tells the app only whether the check passed.

Notifications do not contain health information

Notification text is deliberately written so that nothing sensitive appears on a lock screen. A notification will tell you that something is ready or that you have a message; it will not name a medicine or a health condition.

Permissions we ask for

PermissionAppWhy we ask
CameraBothDelivery proof photos (staff); scanning a prescription token (patient)
LocationPHQ TeamConfirming you are at the pharmacy when you clock in or out
NotificationsBothShift, message and order updates
Face ID / Touch IDBothUnlocking the app without typing a password

Every one of these is optional. You can refuse or later withdraw any of them in your device settings, and the app keeps working with that feature turned off.

Deleting your account from the apps

You can delete your account from inside either app, without contacting us.

In both apps, open Settings (the gear at the top of the screen) and choose “Delete my account”. In PHQ Team, this removes your sign-in, your membership of every pharmacy you belong to in the app, the link between your sign-in and your staff card, and your notification tokens. It does not delete your pharmacy’s employee records of you (rosters, hours, leave and pay), which Australian workplace law requires the pharmacy to keep for seven years; those belong to the pharmacy, not to your app account. A pharmacy owner’s sign-in is the pharmacy’s own account, so it is closed from the web app rather than from a phone: under Settings in the sidebar, cancel the subscription in Manage plan, then choose Leave a pharmacy. Once the owner is the pharmacy’s only member, leaving deletes the pharmacy.

In the patient app, it removes your sign-in, the link between your account and the pharmacy’s record of you, your stored consent, the record of your device, and your notification tokens. After it completes, no login can reach that record.

It does not delete your pharmacy’s own records of your prescriptions or your conversations with them. Those are the pharmacy’s health and business records, and Australian law requires the pharmacy to keep them for a set period. That is the pharmacy’s data, not your app account’s, and section 6 explains how long it is kept.

What the apps do not do

10. Children's privacy

Pharmacy HQ is a professional business tool intended for use by adults aged 18 and over. We do not knowingly collect personal information from anyone under 18. If you believe a minor has created an account, please contact us at privacy@pharmacyhq.com.au and we will promptly delete the account.

11. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes to our practices or applicable law. When we make material changes, we will:

Continued use of Pharmacy HQ after the effective date of any changes constitutes your acceptance of the updated policy.

12. Contact us

For any privacy-related questions, requests, or complaints:

We aim to respond to all privacy enquiries within 5 business days.

Office of the Australian Information Commissioner (OAIC)
If you are not satisfied with our response to a privacy complaint, you may contact the OAIC:
Website: www.oaic.gov.au  ·  Phone: 1300 363 992  ·  GPO Box 5218, Sydney NSW 2001