Privacy Policy

This policy is issued by [registered legal entity name][F] (“Farmacy OS”, “we”, “us”), registered at [registered EU business address][F]. It satisfies our transparency obligations under Articles 13 and 14 of the EU GDPR.

It covers personal data we handle when a pharmacy uses the Farmacy OSplatform, when we run the growth loop on a pharmacy’s behalf, and when anyone visits our marketing site or requests a demo. Cookies are covered separately in our Cookie Policy.

Farmacy OS wears two hats, and it matters which one applies to a given piece of data:

• Processor— for the pharmacy’s own customer, order and clienteling data. The pharmacy is the controller; we act only on its documented instructions under a signed Data Processing Agreement.
• Controller — for the pharmacy account itself: the staff logins, billing records, product telemetry, security logs, and the aggregated learning loop we use to improve the platform.

We keep collection tight. By category:

A pharmacy’s customer records can imply health information, which may be special-category data under GDPR Article 9. We treat it accordingly:

• Data minimisation is mandatory — we collect the minimum that earns its keep.
• Processing needs both an Article 6 basis and an Article 9 condition, determined per purpose and country.
• We complete a DPIA before production processing and keep it living as workflows change.
• We never use a pharmacy's customer data to train shared models without a separate, documented basis.

• Contract (Art. 6(1)(b)) — to provide the platform to your pharmacy.
• Legitimate interests (Art. 6(1)(f)) — security, fraud prevention, and improving the service, balanced against your rights.
• Legal obligation (Art. 6(1)(c)) — tax, accounting and regulatory record-keeping.
• Consent (Art. 6(1)(a) / Art. 9(2)(a)) — where required, e.g. non-essential analytics and certain customer communications; withdrawable at any time.

• EU residency. EU customer data is hosted in the EU — EU — Ireland (eu-west-1) — on managed Postgres.
• Tenant isolation.Every pharmacy is an isolated tenant. Access is enforced in application code and backstopped by Postgres Row-Level Security — one pharmacy can never read another’s data.
• Encryption. AES-256 at rest, TLS 1.3 in transit; the most sensitive fields use envelope encryption with keys held in a managed KMS.
• Dedicated option. Strict-residency tenants can be graduated to a dedicated EU database.

We use a small set of vetted providers to run the platform. Each is bound by a DPA and, where relevant, EU Standard Contractual Clauses. This list is representative of our core stack; the live, maintained list governs.

• Account & ledger data — for the life of the subscription, then deleted or returned per the DPA.
• Billing & tax records — as long as law requires (typically several years).
• Security & audit logs — a limited, defined window sufficient for investigation.
• Demo requests & marketing contacts — until you ask us to erase them, or they go stale.

Under GDPR you can exercise the rights to:

We keep EU data in the EU by default. Where a provider processes data outside the EU (for example, some AI inference), we rely on EU Standard Contractual Clauses, complete a transfer impact assessment, and apply supplementary measures such as encryption and, where offered, zero-data-retention routing. Special-category data does not leave the EU without these safeguards.

• Encryption at rest and in transit; KMS-held keys for sensitive fields.
• Tenant-scoped access end to end — identity propagates through every service and tool call.
• Per-tenant, reason-logged audit trails; time-boxed break-glass support access, never silent cross-tenant reads.
• Least-privilege access, dependency scanning, and testing before scale.
• A breach-response process with notification without undue delay where required.

Questions or requests: farmacie@farmacy-growth.com. Data-protection matters: farmacie@farmacy-growth.com.

You also have the right to lodge a complaint with your local supervisory authority. We’d appreciate the chance to resolve it with you first.