pH7 Terms and Conditions

Last updated July 2026

Global Terms and Conditions

GLOBAL TERMS AND CONDITIONS

Last Updated: July 2026

1. INTRODUCTION

1.1 About these Terms

These Global Terms and Conditions (”Terms”) govern your access to and use of the pH7 platform (the “Platform”).

The Platform is a healthcare technology service that enables patients to connect with independent healthcare professionals and licensed pharmacies through secure digital tools.

These Terms apply to all users of the Platform, regardless of their country of residence.

Additional legal, regulatory and consumer protection requirements applicable to individual jurisdictions are contained within the relevant Country Schedule, which forms part of these Terms.

By creating an account or using the Platform, you agree to be bound by:

  • these Global Terms;

  • the applicable Country Schedule;

  • our Privacy Policy; and

  • any other policies expressly incorporated by reference.

If you do not agree with these Terms, you must not use the Platform.

1.2 Purpose of the Platform

The Platform has been developed to simplify access to regulated healthcare services by providing secure technology that facilitates communication between patients, independent healthcare professionals and licensed pharmacies.

Depending on the jurisdiction in which you use the Platform, the services available may include:

  • identity verification;

  • appointment booking;

  • secure messaging;

  • video and telephone consultations;

  • electronic health questionnaires;

  • prescription management;

  • prescription transmission;

  • pharmacy selection;

  • payment processing;

  • order tracking;

  • delivery notifications; and

  • other healthcare-related administrative services.

Availability of individual services varies between countries and is described within the relevant Country Schedule.

1.3 Nature of the Platform

pH7 is a healthcare technology company.

Unless expressly stated otherwise within a Country Schedule, pH7:

  • is not a hospital;

  • is not a medical practice;

  • is not a healthcare provider;

  • is not a pharmacy;

  • is not a medicines manufacturer;

  • does not practise medicine;

  • does not prescribe medicines;

  • does not diagnose medical conditions;

  • does not determine appropriate treatment;

  • does not influence clinical decision making; and

  • does not dispense medicines.

The Platform provides technology only.

Healthcare services are provided solely by independent licensed healthcare professionals.

Medicines are supplied solely by independent licensed pharmacies.

Clinical responsibility always remains with the treating healthcare professional.

Dispensing responsibility always remains with the dispensing pharmacy.

1.4 Independent Healthcare Professionals

Healthcare professionals using the Platform operate independently.

They are solely responsible for:

  • determining whether to accept a patient;

  • obtaining informed consent where required;

  • conducting consultations;

  • making diagnoses;

  • determining appropriate investigations;

  • deciding whether treatment is clinically appropriate;

  • issuing prescriptions where legally permitted;

  • maintaining clinical records;

  • arranging referrals;

  • complying with professional standards; and

  • complying with all laws and regulatory requirements applicable to their profession.

Nothing within the Platform permits pH7 to direct, influence or interfere with the professional judgement of any healthcare professional.

1.5 Independent Pharmacies

Pharmacies connected to the Platform operate independently.

Each pharmacy remains solely responsible for:

  • verifying prescriptions;

  • complying with pharmaceutical legislation;

  • determining whether medicines may legally be supplied;

  • maintaining dispensing records;

  • counselling patients where required;

  • packaging and dispatching medicines;

  • delivery arrangements; and

  • compliance with applicable pharmacy regulations.

The inclusion of a pharmacy on the Platform does not constitute an endorsement by pH7.

1.6 Acceptance of these Terms

By registering for an account or using the Platform you confirm that:

  • you have read these Terms;

  • you understand these Terms;

  • you agree to comply with these Terms;

  • you agree to the applicable Country Schedule;

  • you have read the Privacy Policy;

  • you have legal capacity to enter into a binding agreement; and

  • all information you provide is accurate and complete.

If you use the Platform on behalf of another person, you confirm that you have the legal authority to do so.

2. DEFINITIONS

For the purposes of these Terms:

Account means your registered user account.

Consultation means any consultation facilitated through the Platform, including video, telephone, messaging or other approved communication methods.

Country Schedule means the jurisdiction-specific terms applicable to your country of residence.

Healthcare Professional means an independent clinician licensed to practise within the relevant jurisdiction.

Medication means any medicine, medical device or regulated healthcare product prescribed or recommended by a Healthcare Professional.

Patient means an individual using the Platform to obtain healthcare-related services.

Pharmacy means an independent licensed pharmacy connected to the Platform.

Platform means all pH7 applications, websites, APIs, software and digital services.

Prescription means a lawful prescription issued solely by a Healthcare Professional.

Privacy Policy means the privacy policy published by pH7 from time to time.

Services means the technology services provided by pH7.

User means any person accessing or using the Platform.

3. ELIGIBILITY

3.1 Eligibility

To use the Platform you must:

  • be at least 18 years of age, or the legal age required in your jurisdiction;

  • have legal capacity to enter into contracts;

  • use the Platform only where permitted by applicable law;

  • provide truthful information; and

  • comply with these Terms.

Certain services may have additional eligibility requirements within the relevant Country Schedule.

3.2 Personal Use

Unless expressly authorised by law, the Platform may only be used for your own healthcare.

You may only create an account for another individual where you are legally authorised to act on their behalf, including as a parent, guardian or attorney.

3.3 Restricted Jurisdictions

The Platform may not be available in every country.

pH7 reserves the right to restrict or refuse access where required by applicable law or regulatory requirements.

4. ACCOUNT REGISTRATION

4.1 Creating an Account

To access certain Services you must create an Account.

You agree to provide accurate, complete and current information during registration.

You are responsible for ensuring that your information remains accurate throughout your use of the Platform.

4.2 Identity Verification

Where required by law, regulation, fraud prevention measures or clinical requirements, pH7 may require identity verification before allowing access to certain Services.

Verification may include:

  • government-issued identification;

  • proof of address;

  • biometric verification;

  • facial recognition;

  • electronic identity checks; or

  • other verification methods permitted by law.

Failure to complete verification may prevent access to some or all Platform Services.

4.3 One Account Policy

Each individual may maintain only one personal account unless expressly authorised by pH7.

Duplicate, fraudulent or misleading accounts may be suspended or permanently removed.

4.4 Account Security

You are responsible for maintaining the confidentiality of your login credentials.

You must:

  • use a secure password;

  • keep your credentials confidential;

  • enable multi-factor authentication where available;

  • notify pH7 immediately of any suspected unauthorised access; and

  • log out of shared devices.

You remain responsible for all activity carried out through your Account unless caused by a security failure attributable to pH7.

4.5 Suspension of Registration

pH7 may refuse registration or suspend an Account where it reasonably believes:

  • false information has been provided;

  • identity cannot be verified;

  • fraud has occurred;

  • the Platform is being misused;

  • applicable laws prohibit continued access; or

  • continued access presents a security or regulatory risk.

Where reasonably possible, pH7 will notify you of the reasons for suspension.

5. COUNTRY SCHEDULES

These Global Terms apply to all users.

Additional legal and regulatory requirements applicable to your country of residence are contained within the relevant Country Schedule.

Each Country Schedule forms an integral part of these Terms.

Current schedules include:

  • Schedule A – United Kingdom

  • Schedule B – Portugal

  • Schedule C – Australia

Where there is any conflict between these Global Terms and a Country Schedule, the Country Schedule shall prevail to the extent necessary to comply with applicable local law.

6. PLATFORM SERVICES

6.1 Services Provided

The Platform provides technology that facilitates access to healthcare services delivered by independent Healthcare Professionals and licensed Pharmacies.

Subject to availability, applicable law and the relevant Country Schedule, the Platform may enable Users to:

  • create and manage an Account;

  • complete identity verification;

  • submit medical questionnaires;

  • upload supporting medical documentation;

  • schedule Consultations;

  • communicate securely with Healthcare Professionals;

  • participate in video, telephone or messaging Consultations;

  • receive Prescriptions where clinically appropriate;

  • transmit Prescriptions to participating Pharmacies;

  • select a Pharmacy for fulfilment where available;

  • pay consultation fees and other applicable Platform charges;

  • receive notifications relating to appointments, prescriptions and orders;

  • access consultation summaries and related documentation; and

  • use any additional services introduced from time to time.

The services available may differ between jurisdictions.

6.2 Technology Platform Only

The Platform facilitates communication and administration.

pH7 does not:

  • provide medical advice;

  • diagnose illness;

  • prescribe medicines;

  • determine treatment plans;

  • guarantee that treatment will be provided;

  • guarantee that a Prescription will be issued;

  • guarantee that medication will be available; or

  • guarantee that a Pharmacy will accept or dispense any Prescription.

Healthcare decisions remain solely with the treating Healthcare Professional.

Dispensing decisions remain solely with the selected Pharmacy.

6.2A Automated Clinical Decision-Making

pH7 does not use automated decision-making or artificial intelligence to make clinical decisions on behalf of Healthcare Professionals.

6.3 Changes to Services

pH7 may add, remove, suspend or modify Platform features where reasonably necessary to:

  • improve functionality;

  • comply with applicable law;

  • improve security;

  • respond to regulatory requirements;

  • address technical issues; or

  • improve user experience.

Where a change materially affects Users, pH7 will provide reasonable notice where practicable.

7. CONSULTATIONS

7.1 Booking Consultations

Consultations are booked through the Platform.

Appointments remain subject to:

  • clinician availability;

  • identity verification;

  • payment of applicable fees;

  • regulatory requirements; and

  • any additional clinical screening considered necessary.

Confirmation of a booking does not guarantee that treatment or a Prescription will be provided.

7.2 Nature of Consultations

Consultations may be conducted by:

  • secure video;

  • telephone;

  • secure messaging; or

  • other approved communication methods.

The consultation format may vary depending upon:

  • clinical judgement;

  • applicable law;

  • the nature of the condition;

  • technology availability; and

  • the relevant Country Schedule.

7.3 Patient Responsibilities During Consultations

You agree to:

  • provide complete and accurate medical information;

  • answer questions honestly;

  • disclose all relevant medications and medical conditions;

  • notify the Healthcare Professional of any allergies or adverse reactions;

  • participate in the Consultation in good faith; and

  • follow reasonable clinical instructions.

Failure to provide accurate information may affect clinical decisions and patient safety.

7.4 Missed Appointments

If you fail to attend a scheduled Consultation without cancelling in accordance with the applicable cancellation policy:

  • your consultation fee may not be refundable;

  • your appointment may be cancelled; and

  • repeated failures to attend may result in restrictions on future bookings.

Applicable cancellation periods are set out during the booking process and may differ between jurisdictions.

7.5 Emergency Medical Situations

The Platform is not an emergency medical service.

You must not use the Platform for:

  • medical emergencies;

  • life-threatening conditions;

  • severe chest pain;

  • severe breathing difficulties;

  • loss of consciousness;

  • stroke symptoms;

  • major trauma; or

  • any condition requiring immediate emergency treatment.

If you believe you require urgent medical care, you should immediately contact your local emergency services or attend the nearest emergency department.

8. HEALTHCARE PROFESSIONALS

8.1 Independent Practice

Healthcare Professionals using the Platform are independent practitioners.

Nothing in these Terms creates:

  • employment;

  • partnership;

  • agency;

  • joint venture; or

  • representative authority

between pH7 and any Healthcare Professional.

8.2 Clinical Independence

Healthcare Professionals retain complete professional independence.

They are solely responsible for:

  • patient assessment;

  • diagnosis;

  • prescribing;

  • treatment recommendations;

  • referrals;

  • follow-up care;

  • medical record keeping;

  • obtaining informed consent where required; and

  • compliance with applicable professional standards.

pH7 cannot direct or influence these decisions.

8.2A Clinical Records

Healthcare Professionals remain responsible for creating and maintaining any clinical records required under applicable law and professional standards.

8.3 No Guarantee of Treatment

Healthcare Professionals may determine that:

  • treatment is not clinically appropriate;

  • additional information is required;

  • further investigations are necessary;

  • referral is appropriate; or

  • no Prescription should be issued.

You acknowledge that no consultation guarantees:

  • treatment;

  • medication;

  • referral;

  • diagnosis; or

  • ongoing care.

8.4 Professional Standards

Healthcare Professionals are expected to maintain all licences, registrations and professional qualifications required within the jurisdictions in which they practise.

Where appropriate, pH7 may undertake verification of professional registration before permitting access to the Platform.

Such verification does not constitute an endorsement or guarantee of competence.

9. PRESCRIPTIONS

9.1 Clinical Decision

Prescriptions are issued solely at the discretion of the treating Healthcare Professional.

Neither pH7 nor any Pharmacy may require, request or influence the issuance of a Prescription.

9.2 No Right to Medication

Use of the Platform does not create any entitlement to receive:

  • medication;

  • repeat prescriptions;

  • controlled medicines;

  • specialist medicines; or

  • any particular treatment.

All Prescriptions remain subject to applicable law and professional judgement.

9.3 Prescription Validity

Patients remain responsible for ensuring that Prescriptions are used lawfully and within any applicable validity period.

Expired Prescriptions may not be accepted by Pharmacies.

9.4 Prescription Transmission

Where supported, the Platform may securely transmit Prescription information to a participating Pharmacy selected by the Patient or Healthcare Professional in accordance with applicable law.

Prescription transmission does not constitute acceptance of the Prescription by the receiving Pharmacy.

9.4A Electronic Prescribing

Where electronic prescribing is permitted under applicable legislation, prescriptions may be transmitted electronically using approved systems.

10. PHARMACIES

10.1 Independent Pharmacies

Pharmacies using the Platform operate independently.

Each Pharmacy remains solely responsible for:

  • verifying Prescriptions;

  • determining whether medicines may legally be supplied;

  • stock availability;

  • dispensing accuracy;

  • counselling patients where required;

  • packaging;

  • dispatch;

  • delivery; and

  • compliance with applicable pharmaceutical legislation.

10.2 Pharmacy Acceptance

A Pharmacy may refuse to dispense a Prescription where permitted by law, including where:

  • legal requirements have not been satisfied;

  • stock is unavailable;

  • clarification from the prescriber is required;

  • patient verification cannot be completed; or

  • dispensing would otherwise be unlawful or clinically inappropriate.

pH7 has no authority to require a Pharmacy to dispense medication.

10.2A Pharmacy Independence

The Pharmacy independently determines whether a prescription satisfies all legal and professional dispensing requirements and may refuse to dispense where required by law or professional judgement.

10.3 Delivery Services

Where delivery services are available, delivery is arranged by the dispensing Pharmacy or its delivery partners.

Estimated delivery times are indicative only.

pH7 does not guarantee delivery dates unless expressly stated.

10.4 Medication Availability

Medication availability varies between countries, suppliers and Pharmacies.

pH7 does not warrant that:

  • any particular medication will be available;

  • substitute products will be available;

  • prices will remain unchanged; or

  • supply interruptions will not occur.

10.5 Product Information

Any information displayed within the Platform relating to medicines or healthcare products is provided for general informational purposes only.

Such information does not constitute:

  • medical advice;

  • a recommendation;

  • an advertisement for prescription medicines where prohibited by law; or

  • a guarantee that a Healthcare Professional will prescribe any product.

Treatment decisions remain entirely with the treating Healthcare Professional.

11. COMMUNICATIONS

11.1 Secure Communications

The Platform provides secure methods of communication between Patients, Healthcare Professionals and participating Pharmacies.

Users agree to use these communication channels responsibly and only for legitimate healthcare purposes.

11.2 Platform Notifications

By using the Platform, you consent to receiving operational communications relating to:

  • appointments;

  • identity verification;

  • consultations;

  • prescriptions;

  • orders;

  • payments;

  • account security;

  • regulatory notices; and

  • important service updates.

Marketing communications will be managed separately in accordance with your communication preferences and applicable law.

12. FEES, PAYMENTS AND REFUNDS

12.1 Consultation Fees

Consultation fees are displayed before a booking is confirmed.

By confirming a booking, you authorise pH7 or its authorised payment provider to collect the applicable fees.

Fees may vary depending on:

  • jurisdiction;

  • consultation type;

  • Healthcare Professional;

  • appointment duration; or

  • other factors communicated before payment.

All prices include applicable taxes where required by law unless otherwise stated.

12.2 Payment Processing

Payments are processed through independent regulated payment service providers.

pH7 does not store full payment card details.

By making a payment, you authorise the applicable payment provider to process the transaction in accordance with its own terms and privacy policy.

12.3 Pharmacy Charges

Unless expressly stated otherwise:

  • consultation fees do not include medication costs;

  • medication costs are determined by the dispensing Pharmacy;

  • delivery charges may apply;

  • additional pharmacy fees may apply where permitted by law.

Payment for medication may be collected either by the Pharmacy or through the Platform, depending on the relevant Country Schedule.

12.4 Refunds

Refund eligibility depends upon the circumstances of each booking and the applicable Country Schedule.

Refunds may be available where:

  • the Healthcare Professional cancels the Consultation;

  • the Platform is unable to provide the booked service due to a technical failure attributable to pH7;

  • payment has been taken in error; or

  • applicable consumer law requires a refund.

Refunds will generally not be available where:

  • the Patient fails to attend the Consultation;

  • the Patient cancels outside the permitted cancellation period;

  • a Healthcare Professional determines that treatment or a Prescription is not clinically appropriate; or

  • medication is unavailable after a lawful clinical assessment.

Nothing in these Terms limits any statutory consumer rights that cannot legally be excluded.

12.5 Chargebacks

If you initiate an unjustified chargeback or payment dispute after receiving Platform Services, pH7 reserves the right to:

  • recover any unpaid amounts;

  • suspend your Account;

  • recover reasonable administrative costs where permitted by law; and

  • defend any payment dispute.

13. PATIENT RESPONSIBILITIES

13.1 Accurate Information

You must provide accurate, complete and truthful information at all times.

This includes:

  • identity information;

  • contact information;

  • medical history;

  • current medications;

  • allergies;

  • symptoms;

  • previous diagnoses; and

  • any other information reasonably requested by a Healthcare Professional.

Failure to provide accurate information may compromise patient safety and affect clinical decisions.

13.2 Updating Information

You agree to promptly update your information where there are material changes, including:

  • change of address;

  • change of contact details;

  • new medications;

  • new diagnoses;

  • pregnancy where clinically relevant;

  • significant adverse reactions; or

  • any information that could reasonably affect ongoing treatment.

13.3 Following Clinical Advice

Healthcare Professionals provide treatment recommendations based upon the information available at the time of consultation.

You remain responsible for deciding whether to follow that advice.

Where treatment is commenced, you should:

  • follow dosage instructions;

  • attend recommended follow-up appointments;

  • report adverse effects promptly; and

  • seek emergency care where appropriate.

13.4 Responsible Use of Prescriptions

You agree that you will not:

  • obtain medication fraudulently;

  • alter Prescriptions;

  • share medication with others;

  • sell prescribed medication;

  • use medication other than as prescribed;

  • attempt to obtain duplicate Prescriptions through deception; or

  • otherwise misuse regulated medicines.

Misuse of Prescriptions may result in suspension of your Account and reporting to relevant authorities where required by law.

13.5 Respectful Behaviour

You must treat:

  • Healthcare Professionals;

  • Pharmacy staff;

  • pH7 employees;

  • contractors; and

  • other Platform Users

with courtesy and respect.

Abusive, threatening, discriminatory or inappropriate behaviour will not be tolerated.

14. ACCEPTABLE USE

14.1 Lawful Use

You agree to use the Platform only for lawful purposes.

You must comply with:

  • applicable laws;

  • professional requirements;

  • regulatory obligations; and

  • these Terms.

14.2 Prohibited Activities

You must not:

  • provide false information;

  • impersonate another person;

  • create multiple fraudulent Accounts;

  • interfere with Platform security;

  • attempt unauthorised access;

  • upload malicious software;

  • reverse engineer the Platform;

  • scrape or harvest Platform data;

  • interfere with other Users;

  • pressure Healthcare Professionals into issuing Prescriptions;

  • use automated software or bots without permission;

  • infringe intellectual property rights;

  • engage in fraudulent payment activity;

  • abuse customer support staff; or

  • use the Platform for any unlawful purpose.

14.3 Communications

You must not use Platform communications to:

  • harass;

  • threaten;

  • intimidate;

  • advertise;

  • solicit business;

  • distribute spam;

  • send malicious content; or

  • engage in unlawful activity.

14.4 Security

You must not attempt to:

  • bypass Platform security;

  • test vulnerabilities without permission;

  • interfere with authentication systems;

  • overload Platform infrastructure;

  • gain unauthorised access to data;

  • intercept communications; or

  • compromise Platform integrity.

15. INTELLECTUAL PROPERTY

15.1 Ownership

Unless otherwise stated, all intellectual property relating to the Platform, including:

  • software;

  • source code;

  • databases;

  • trademarks;

  • logos;

  • graphics;

  • text;

  • designs;

  • documentation;

  • APIs; and

  • content,

is owned by or licensed to pH7.

All rights are reserved.

15.2 Limited Licence

Subject to these Terms, pH7 grants you a limited, non-exclusive, non-transferable, revocable licence to use the Platform solely for your personal healthcare purposes.

This licence does not transfer ownership of any intellectual property.

15.3 Restrictions

You may not:

  • copy;

  • modify;

  • distribute;

  • reproduce;

  • commercialise;

  • sublicense;

  • reverse engineer;

  • decompile;

  • extract source code; or

  • create derivative works,

except where expressly permitted by applicable law.

16. THIRD-PARTY SERVICES

16.1 Third-Party Providers

The Platform may integrate with independent third-party providers, including:

  • payment providers;

  • identity verification providers;

  • cloud hosting providers;

  • notification services;

  • pharmacies;

  • Healthcare Professionals; and

  • logistics providers.

Each third party operates independently and may be subject to its own terms and privacy policies.

16.2 Third-Party Websites

The Platform may contain links to external websites.

pH7 is not responsible for:

  • their availability;

  • their accuracy;

  • their security;

  • their content; or

  • their privacy practices.

Accessing third-party websites is at your own risk.

16.3 No Endorsement

The inclusion of any third-party provider within the Platform does not constitute:

  • endorsement;

  • recommendation;

  • certification; or

  • guarantee

by pH7.

Users should make their own decisions regarding the services provided by independent Healthcare Professionals and Pharmacies.

17. PRIVACY AND DATA PROTECTION

17.1 Commitment to Privacy

pH7 is committed to protecting the privacy, confidentiality and security of personal information.

Personal data is processed in accordance with applicable data protection laws, including those set out in the relevant Country Schedule and our Privacy Policy.

The Privacy Policy forms part of these Terms.

17.2 Personal Data

In order to provide the Services, pH7 may process personal information including:

  • identity information;

  • contact details;

  • account information;

  • payment information;

  • appointment information;

  • technical information;

  • device information;

  • communications;

  • identity verification information; and

  • other information necessary to provide the Services.

Where permitted or required by law, Healthcare Professionals and Pharmacies may also process health information through the Platform.

17.3 Health Information

Health information is considered sensitive personal information.

Such information is processed only where permitted by applicable law and only to facilitate healthcare services requested by the Patient.

Health information may include:

  • medical history;

  • symptoms;

  • diagnoses;

  • medications;

  • allergies;

  • consultation notes;

  • Prescriptions;

  • laboratory results;

  • referral information; and

  • other healthcare information provided by the Patient or Healthcare Professional.

17.4 Data Sharing

Subject to applicable law, information may be shared where reasonably necessary with:

  • Healthcare Professionals;

  • Pharmacies;

  • identity verification providers;

  • payment providers;

  • cloud service providers;

  • regulatory authorities;

  • law enforcement agencies;

  • professional advisers; and

  • other service providers supporting the operation of the Platform.

Information is shared only where reasonably necessary for the provision of the Services or where required by law.

17.5 Security

pH7 implements appropriate technical and organisational measures designed to protect information against:

  • unauthorised access;

  • accidental loss;

  • misuse;

  • destruction;

  • alteration; and

  • unlawful disclosure.

Security measures may include:

  • encryption;

  • role-based access controls;

  • multi-factor authentication;

  • audit logging;

  • vulnerability testing;

  • penetration testing;

  • security monitoring;

  • backup systems; and

  • incident response procedures.

No electronic system can be guaranteed to be completely secure.

17.5A Cybersecurity Controls

pH7 applies cybersecurity controls including encryption in transit, encryption at rest, role-based access controls, audit logging and regular security monitoring.

17.6 Data Retention

Information is retained only for as long as reasonably necessary:

  • to provide the Services;

  • to comply with legal obligations;

  • to resolve disputes;

  • to maintain healthcare records where required; or

  • to enforce these Terms.

Retention periods vary between jurisdictions and are described in the applicable Country Schedule and Privacy Policy.

17.7 International Transfers

Where information is transferred internationally, pH7 will implement appropriate safeguards required by applicable law.

18. CONFIDENTIALITY

18.1 Patient Confidentiality

Information exchanged through the Platform is intended to remain confidential.

Healthcare Professionals remain independently responsible for complying with their professional duties of confidentiality.

18.2 Platform Confidentiality

Users agree not to disclose confidential information relating to:

  • Platform security;

  • software;

  • technical documentation;

  • commercial information;

  • pricing;

  • business processes; or

  • other confidential information obtained through use of the Platform,

except where disclosure is required by law.

18.3 Lawful Disclosure

Nothing in these Terms prevents disclosure where required:

  • by law;

  • by a court;

  • by a regulator;

  • for safeguarding purposes;

  • to prevent serious harm; or

  • to protect the legal rights of pH7 or another person.

18.4 Regulatory Cooperation

pH7 will cooperate with lawful requests made by competent regulatory authorities where required by applicable law.

19. MEDICAL DISCLAIMER

19.1 Technology Platform

The Platform is a healthcare technology platform.

pH7 does not provide medical care.

All healthcare services are provided solely by independent Healthcare Professionals.

19.2 Clinical Responsibility

All decisions regarding:

  • diagnosis;

  • investigations;

  • treatment;

  • prescribing;

  • referrals;

  • monitoring; and

  • follow-up care

remain exclusively the responsibility of the treating Healthcare Professional.

pH7 does not review, approve or alter clinical decisions.

19.3 No Guarantee of Treatment

Use of the Platform does not guarantee:

  • access to a Healthcare Professional;

  • a diagnosis;

  • treatment;

  • medication;

  • repeat prescriptions;

  • specialist referrals;

  • ongoing care; or

  • any particular clinical outcome.

Each Consultation is assessed independently.

19.4 Patient Responsibility

Patients remain responsible for:

  • providing accurate information;

  • following medical advice where appropriate;

  • seeking emergency treatment where necessary;

  • attending follow-up appointments; and

  • informing Healthcare Professionals of changes in their health.

19.5 Emergency Care

The Platform must not be used for emergency medical situations.

If you believe you require emergency medical assistance, contact your local emergency services immediately.

20. LIMITATION OF LIABILITY

20.1 Nothing Excluded Unlawfully

Nothing in these Terms excludes or limits liability where such exclusion or limitation would be unlawful.

This includes any liability that cannot legally be excluded under applicable consumer protection or healthcare legislation.

20.2 Platform Services

To the maximum extent permitted by law, pH7 shall not be liable for losses arising from:

  • decisions made by Healthcare Professionals;

  • acts or omissions of Pharmacies;

  • medication shortages;

  • delays in delivery;

  • regulatory restrictions;

  • interruption of third-party services;

  • internet failures;

  • user equipment failures;

  • inaccurate information supplied by Users; or

  • circumstances outside the reasonable control of pH7.

20.3 Clinical Services

Healthcare Professionals remain solely responsible for the clinical services they provide.

Nothing in these Terms transfers clinical responsibility to pH7.

20.4 Pharmacy Services

Pharmacies remain solely responsible for:

  • dispensing;

  • medication quality;

  • counselling;

  • storage;

  • transportation;

  • delivery; and

  • compliance with pharmaceutical legislation.

20.5 Indirect Loss

To the maximum extent permitted by applicable law, pH7 shall not be liable for indirect, incidental, consequential or special damages including:

  • loss of profits;

  • loss of opportunity;

  • business interruption;

  • reputational damage; or

  • loss of data,

except where liability cannot lawfully be excluded.

20.6 Maximum Liability

Where permitted by law, the aggregate liability of pH7 arising out of or relating to the Services shall not exceed the total fees paid by the User to pH7 during the twelve (12) months immediately preceding the event giving rise to the claim.

This limitation does not apply where prohibited by applicable law.

21. INDEMNITY

You agree to indemnify and hold harmless pH7, its directors, officers, employees, contractors and affiliates from claims, losses, liabilities, damages, costs and expenses arising from:

  • your breach of these Terms;

  • fraudulent activity;

  • unlawful conduct;

  • misuse of the Platform;

  • infringement of intellectual property rights;

  • misuse of Prescriptions;

  • unauthorised access to your Account resulting from your failure to protect your credentials; or

  • information knowingly provided by you that is false or misleading.

This indemnity applies only to the extent permitted by applicable law.

22. INSURANCE

Healthcare Professionals and Pharmacies are responsible for maintaining any professional indemnity insurance or other insurance required by applicable law or professional regulation.

Unless expressly stated otherwise in the applicable Country Schedule, pH7 does not provide professional indemnity insurance on behalf of independent Healthcare Professionals or Pharmacies.

23. SUSPENSION AND TERMINATION

23.1 Suspension

pH7 may suspend or restrict access to all or part of the Platform where it reasonably believes that:

  • these Terms have been breached;

  • false or misleading information has been provided;

  • fraudulent activity has occurred or is suspected;

  • your Account has been compromised;

  • continued access presents a security risk;

  • continued access presents a regulatory or legal risk;

  • you have failed to comply with applicable laws;

  • payment obligations remain outstanding; or

  • suspension is necessary to protect Patients, Healthcare Professionals, Pharmacies or the Platform.

Where reasonably practicable, pH7 will notify you of the reasons for suspension.

23.2 Termination by You

You may close your Account at any time by contacting pH7 or using any account deletion functionality made available within the Platform.

Closure of your Account does not affect:

  • completed Consultations;

  • outstanding payment obligations;

  • ongoing legal obligations;

  • healthcare records required by law to be retained; or

  • rights accrued before termination.

23.3 Termination by pH7

pH7 may terminate your Account immediately where:

  • fraudulent activity is identified;

  • repeated misuse of the Platform occurs;

  • unlawful activity is detected;

  • abuse or harassment of Healthcare Professionals, Pharmacy staff or pH7 personnel occurs;

  • continued access creates unacceptable legal or regulatory risk; or

  • continued operation of your Account is prohibited by law.

Where appropriate, pH7 may instead issue warnings or temporarily suspend your Account before termination.

23.4 Effect of Termination

Following termination:

  • your right to use the Platform immediately ends;

  • you may lose access to your Account;

  • outstanding payments remain payable;

  • information may continue to be retained where required by law;

  • certain contractual provisions will continue to apply.

Termination does not affect any legal rights or remedies accrued before termination.

24. CONSUMER RIGHTS

Nothing in these Terms excludes, limits or restricts any consumer rights that cannot lawfully be excluded under applicable law.

Where mandatory consumer protection legislation provides greater rights than these Terms, those statutory rights shall prevail.

If any provision of these Terms is found to be unenforceable under applicable consumer protection legislation, the remainder of these Terms shall remain in full force and effect.

Nothing in these Terms excludes, restricts or limits any consumer rights that cannot lawfully be excluded under applicable legislation.

25. PLATFORM AVAILABILITY

25.1 Availability

pH7 aims to maintain a secure, reliable and continuously available Platform.

However, uninterrupted availability cannot be guaranteed.

The Platform may occasionally be unavailable due to:

  • scheduled maintenance;

  • software updates;

  • infrastructure upgrades;

  • cyber security incidents;

  • failures of third-party providers;

  • internet outages;

  • telecommunications failures; or

  • events beyond the reasonable control of pH7.

25.2 Maintenance

Where reasonably practicable, planned maintenance will be carried out outside normal operating hours.

Material scheduled maintenance may be notified in advance through the Platform or by email.

25.3 Platform Improvements

pH7 may introduce:

  • new features;

  • improvements;

  • security updates;

  • user interface changes;

  • new functionality; or

  • service enhancements

at any time.

Such changes may alter the appearance or operation of the Platform.

26. FORCE MAJEURE

pH7 shall not be liable for any delay or failure to perform its obligations where such delay or failure results from events beyond its reasonable control, including:

  • natural disasters;

  • pandemics;

  • public health emergencies;

  • war;

  • terrorism;

  • civil unrest;

  • government action;

  • industrial disputes;

  • cyber attacks;

  • failures of utilities;

  • failures of telecommunications infrastructure;

  • failures of cloud service providers; or

  • other unforeseeable events beyond reasonable control.

pH7 will use reasonable efforts to minimise the impact of any Force Majeure Event where practicable.

27. CHANGES TO THESE TERMS

pH7 may amend these Terms where reasonably necessary to:

  • comply with changes in law;

  • comply with regulatory requirements;

  • improve the Platform;

  • improve security;

  • reflect changes to business operations; or

  • introduce new Services.

Where changes materially affect Users, reasonable notice will be provided before the updated Terms become effective.

Continued use of the Platform after the effective date constitutes acceptance of the updated Terms.

If you do not agree to the amended Terms, you must stop using the Platform.

28. GENERAL LEGAL PROVISIONS

28.1 Entire Agreement

These Terms, together with:

  • the applicable Country Schedule;

  • the Privacy Policy; and

  • any policies expressly incorporated by reference,

constitute the entire agreement between you and pH7 relating to your use of the Platform.

They supersede all previous discussions, communications and agreements relating to the same subject matter.

28.2 Severability

If any provision of these Terms is held to be invalid, unlawful or unenforceable, that provision shall be severed to the minimum extent necessary.

The remaining provisions shall remain valid and enforceable.

28.3 Waiver

Failure by pH7 to enforce any provision of these Terms shall not constitute a waiver of that provision or of any other rights.

Any waiver must be made expressly in writing.

28.4 Assignment

pH7 may assign, transfer or novate its rights or obligations under these Terms as part of:

  • a corporate restructuring;

  • merger;

  • acquisition;

  • financing transaction;

  • sale of assets; or

  • business reorganisation,

provided such assignment does not materially reduce your legal rights.

Users may not assign or transfer their rights or obligations without the prior written consent of pH7.

28.5 No Partnership

Nothing in these Terms creates:

  • employment;

  • partnership;

  • agency;

  • joint venture;

  • franchise; or

  • fiduciary relationship

between:

  • pH7 and any Patient;

  • pH7 and any Healthcare Professional; or

  • pH7 and any Pharmacy.

28.6 Electronic Communications

You agree that pH7 may communicate with you electronically regarding:

  • your Account;

  • appointments;

  • payments;

  • regulatory notices;

  • service updates;

  • legal notices; and

  • other operational matters.

Electronic communications satisfy any legal requirement that communications be in writing where permitted by law.

28.7 Electronic Signatures

Where permitted by applicable law, electronic signatures, electronic acceptances and electronic records shall have the same legal effect as handwritten signatures.

28.8 Further Assurance

Each party agrees to execute any documents and perform any acts reasonably necessary to give effect to these Terms.

28.9 Survival

The following provisions survive termination of these Terms:

  • Intellectual Property;

  • Confidentiality;

  • Privacy obligations;

  • Liability;

  • Indemnity;

  • Payment obligations;

  • Dispute Resolution;

  • Governing Law;

  • and any provisions intended by their nature to survive termination.

29. CONTACT DETAILS

For questions relating to these Terms or the Platform, you may contact pH7 using the contact details published on the Platform or within the applicable Country Schedule.

Privacy requests should be submitted using the contact details provided within the Privacy Policy.

Regulatory complaints relating to Healthcare Professionals or Pharmacies should be directed to the appropriate regulator identified in the relevant Country Schedule.

30. COUNTRY SCHEDULES

These Global Terms are supplemented by jurisdiction-specific Country Schedules.

Each Country Schedule forms part of these Terms and applies according to your country of residence or the jurisdiction in which you access the Services.

Current Country Schedules include:

  • Schedule A – United Kingdom

  • Schedule B – Portugal

  • Schedule C – Australia

Each Country Schedule sets out, where applicable:

  • the local pH7 operating entity;

  • applicable healthcare regulations;

  • regulatory authorities;

  • clinician requirements;

  • pharmacy framework;

  • prescription requirements;

  • payment arrangements;

  • consumer rights;

  • complaints procedures;

  • privacy and data protection requirements;

  • governing law; and

  • jurisdiction.

Where there is any inconsistency between these Global Terms and an applicable Country Schedule, the Country Schedule shall prevail to the extent necessary to comply with local law.

SCHEDULE A – UNITED KINGDOM

This United Kingdom Schedule forms part of the pH7 Global Terms and Conditions and applies only where Services are provided within the United Kingdom.

1. APPLICABILITY

This Schedule applies where:

  • you are located in the United Kingdom when using the Platform;

  • your Consultation is provided by a UK-registered Healthcare Professional;

  • your prescription is issued under UK law;

  • your medication is dispensed by a UK pharmacy; or

  • the Services are provided by the UK operating entity.

Where there is any inconsistency between this Schedule and the Global Terms and Conditions, this Schedule shall prevail to the extent required by applicable UK law.

2. UK OPERATING ENTITY

Services within the United Kingdom are provided by:

Tetrodaxol GB Limited

Company Number: 16340858

Registered Office:

Blayds House, 2nd Floor

21 Blayds Yard

Leeds

England

LS1 4AD

Trading as pH7

3. ROLE OF pH7

Within the United Kingdom, pH7 operates solely as a digital healthcare technology platform.

pH7:

  • facilitates patient onboarding and identity verification;

  • provides appointment booking functionality;

  • enables secure communication between Patients and Healthcare Professionals;

  • facilitates secure payment processing;

  • facilitates prescription transmission where authorised by the prescriber and Patient;

  • connects Patients with independent Healthcare Professionals and licensed Pharmacies.

pH7 does not:

  • provide medical advice;

  • diagnose medical conditions;

  • prescribe medicines;

  • determine treatment plans;

  • dispense medicines;

  • manufacture medicines;

  • replace emergency medical services.

All clinical responsibility remains solely with the treating Healthcare Professional.

4. HEALTHCARE PROFESSIONALS

Healthcare Professionals using the Platform must:

  • hold current registration with the General Medical Council (GMC);

  • hold any specialist registration required for their scope of practice;

  • maintain appropriate professional indemnity insurance;

  • comply with Good Medical Practice and all applicable GMC guidance;

  • comply with all applicable prescribing legislation and professional standards;

  • remain solely responsible for all clinical decisions, diagnoses, prescriptions and treatment plans.

pH7 does not influence or interfere with the independent clinical judgement of Healthcare Professionals.

5. REGULATED HEALTHCARE SERVICES

Where regulated healthcare activities are delivered through the Platform, those services must be provided through an appropriately registered healthcare provider where registration is required under UK law.

Healthcare Professionals are responsible for ensuring that regulated clinical activities are undertaken in compliance with the requirements of the Care Quality Commission (CQC) and all applicable legislation.

Unless expressly stated otherwise, pH7 is not the provider of regulated healthcare services.

6. REMOTE CONSULTATIONS

Remote Consultations are conducted in accordance with applicable UK legislation and relevant professional guidance.

Healthcare Professionals determine whether remote assessment is clinically appropriate.

A clinician may:

  • request additional medical records;

  • request supporting documentation;

  • request photographic or diagnostic evidence;

  • request further identity verification;

  • require an in-person consultation;

  • decline to prescribe or provide treatment where clinically appropriate.

Booking or completing a Consultation does not guarantee that a prescription or treatment will be issued.

7. PRESCRIPTIONS

Only the treating Healthcare Professional determines whether issuing a prescription is clinically appropriate.

Where prescribed:

  • prescriptions remain entirely the responsibility of the prescriber;

  • prescriptions may be securely transmitted to a Pharmacy nominated by the Patient where authorised;

  • prescriptions remain subject to all applicable UK legislation and professional guidance.

Healthcare Professionals may refuse to prescribe where they determine this is clinically appropriate.

8. CONTROLLED MEDICINES

Where controlled medicines are prescribed, Healthcare Professionals must comply with all applicable legislation, including:

  • the Misuse of Drugs Act 1971;

  • the Misuse of Drugs Regulations 2001;

  • Home Office requirements;

  • GMC guidance; and

  • any other applicable legal or regulatory requirements.

Neither pH7 nor any Pharmacy may amend, alter or influence a clinician’s prescription.

9. PHARMACIES

Pharmacies available through the Platform must:

  • be appropriately licensed to dispense medicines in the United Kingdom;

  • comply with applicable pharmacy legislation;

  • comply with the standards of the General Pharmaceutical Council (GPhC) where applicable;

  • independently verify every prescription before dispensing.

Dispensing decisions remain solely the responsibility of the Pharmacy.

10. PATIENT VERIFICATION

Patients may be required to complete identity verification before:

  • accessing Platform Services;

  • attending Consultations;

  • receiving prescriptions;

  • obtaining controlled medicines;

  • completing payment transactions; or

  • arranging Pharmacy fulfilment.

Healthcare Professionals may refuse treatment where identity cannot be satisfactorily verified.

11. DATA PROTECTION

Personal data is processed in accordance with:

  • the UK General Data Protection Regulation (UK GDPR);

  • the Data Protection Act 2018;

  • applicable confidentiality obligations;

  • the pH7 Global Privacy Policy.

Special category health information is processed only where a lawful basis exists under applicable legislation.

Where personal data is transferred internationally, appropriate safeguards will be implemented in accordance with applicable data protection law.

12. PAYMENTS

Consultation fees are processed securely through authorised payment providers.

Payment processing is performed solely for facilitating Platform Services.

Healthcare Professionals and Pharmacies remain independently responsible for their own taxation, accounting and regulatory obligations.

13. COMPLAINTS

Clinical complaints should initially be directed to the treating Healthcare Professional or regulated healthcare provider responsible for the Consultation.

Platform-related complaints may be submitted to:

legal@ph7.health

Where appropriate, Patients may also contact the relevant statutory or professional regulator.

14. REGULATORY COMPLIANCE

pH7 is committed to operating in accordance with applicable United Kingdom legislation and guidance relating to:

  • digital healthcare services;

  • remote consultations;

  • controlled medicines;

  • medical confidentiality;

  • data protection;

  • payment processing; and

  • cybersecurity.

Healthcare Professionals and Pharmacies remain independently responsible for compliance with the professional and regulatory obligations applicable to their own practice.

ADDITIONAL UNITED KINGDOM REGULATORY TERMS

The Platform is not intended for emergency medical care. Patients experiencing a medical emergency should immediately contact the appropriate emergency services.

Healthcare Professionals remain responsible for creating and maintaining any clinical records required under applicable law and professional standards.

The Pharmacy independently determines whether a prescription satisfies all legal and professional dispensing requirements and may refuse to dispense where required by law or professional judgement.

pH7 will cooperate with lawful requests made by competent regulatory authorities where required by applicable law.

Nothing in these Terms excludes, restricts or limits any consumer rights that cannot lawfully be excluded under applicable legislation.

pH7 does not use automated decision-making or artificial intelligence to make clinical decisions on behalf of Healthcare Professionals.

Where personal data is transferred internationally, pH7 will implement appropriate safeguards under UK GDPR and applicable UK data protection legislation.

Where electronic prescribing is permitted under applicable legislation, prescriptions may be transmitted electronically using approved systems.

pH7 applies cybersecurity controls including encryption in transit, encryption at rest, role-based access controls, audit logging and regular security monitoring.

Relevant regulator references include:

  • General Medical Council (GMC);

  • Care Quality Commission (CQC);

  • General Pharmaceutical Council (GPhC); and

  • Information Commissioner’s Office (ICO).

15. GOVERNING LAW

This Schedule shall be governed by and construed in accordance with the laws of England and Wales, unless mandatory consumer protection legislation requires otherwise.

16. JURISDICTION

Subject to any mandatory consumer rights under applicable law, the courts of England and Wales shall have exclusive jurisdiction to determine any dispute arising from or relating to this Schedule.

This Schedule should be read together with the pH7 Global Terms and Conditions, Privacy Policy, Cookie Policy, and any applicable country-specific regulatory notices published by pH7.

SCHEDULE B – PORTUGAL

This Portugal Schedule forms part of the pH7 Global Terms and Conditions and applies only where Services are provided within Portugal.

1. APPLICABILITY

This Schedule applies where:

  • you are located in Portugal when using the Platform;

  • your Consultation is provided by a Healthcare Professional authorised to practise in Portugal;

  • your prescription is issued under Portuguese law;

  • your medication is dispensed by a Portuguese pharmacy; or

  • the Services are provided by the Portuguese operating entity.

Where there is any inconsistency between this Schedule and the Global Terms and Conditions, this Schedule shall prevail to the extent required by applicable Portuguese law.

2. PORTUGUESE OPERATING ENTITY

Services within Portugal are provided by:

Tetrodaxol, Unipessoal Lda.

NIPC: 516762184

Registered Office:

Avenida do Brasil 43, 11.Âş Direito

1700-062 Lisboa

Portugal

Trading as pH7

3. ROLE OF pH7

Within Portugal, pH7 operates solely as a digital healthcare technology platform.

pH7:

  • facilitates patient onboarding and identity verification;

  • provides appointment booking functionality;

  • enables secure communication between Patients and Healthcare Professionals;

  • facilitates secure payment processing;

  • facilitates prescription transmission where authorised by the prescriber and Patient;

  • connects Patients with independent Healthcare Professionals and licensed Pharmacies.

pH7 does not:

  • provide medical advice;

  • diagnose medical conditions;

  • prescribe medicines;

  • determine treatment plans;

  • dispense medicines;

  • manufacture medicines;

  • replace emergency medical services.

All clinical responsibility remains solely with the treating Healthcare Professional.

4. HEALTHCARE PROFESSIONALS

Healthcare Professionals using the Platform must:

  • be legally authorised to practise medicine in Portugal;

  • hold valid registration with the Ordem dos MĂ©dicos;

  • maintain any professional indemnity insurance required by applicable law;

  • comply with the CĂłdigo DeontolĂłgico da Ordem dos MĂ©dicos;

  • comply with all applicable Portuguese legislation governing medical practice, prescribing and telemedicine;

  • remain solely responsible for all clinical decisions, diagnoses, prescriptions and treatment plans.

pH7 does not interfere with the independent clinical judgement of Healthcare Professionals.

5. REMOTE CONSULTATIONS

Remote Consultations are conducted in accordance with applicable Portuguese legislation and professional guidance.

Healthcare Professionals determine whether remote assessment is clinically appropriate.

A clinician may:

  • request additional medical records;

  • request supporting documentation;

  • request diagnostic information;

  • request additional identity verification;

  • require an in-person consultation;

  • decline to prescribe where clinically appropriate.

Completion of a Consultation does not guarantee that a prescription or treatment will be issued.

6. MEDICAL CANNABIS PRESCRIBING

Where cannabis-based medicinal products are prescribed, prescribing Healthcare Professionals remain solely responsible for ensuring compliance with all applicable Portuguese legislation, including:

  • Decree-Law No. 8/2019;

  • Law No. 33/2018;

  • applicable INFARMED regulations;

  • all professional obligations of the Ordem dos MĂ©dicos.

Where required by law, prescriptions must be issued using the legally prescribed special prescription model and only for approved medicinal cannabis products and authorised therapeutic indications.

pH7 neither influences nor participates in prescribing decisions.

7. PHARMACIES

Pharmacies available through the Platform must:

  • be legally authorised to dispense medicines in Portugal;

  • comply with applicable Portuguese pharmaceutical legislation;

  • comply with all applicable INFARMED requirements;

  • independently verify every prescription before dispensing;

  • comply with all legal requirements relating to controlled medicines and medicinal cannabis where applicable.

Dispensing decisions remain solely the responsibility of the Pharmacy.

8. PATIENT VERIFICATION

Patients may be required to complete identity verification before:

  • accessing Platform Services;

  • attending Consultations;

  • receiving prescriptions;

  • obtaining controlled medicines;

  • completing payment transactions; or

  • arranging Pharmacy fulfilment.

Healthcare Professionals may refuse treatment where identity cannot be satisfactorily verified.

Where required by Portuguese law, Pharmacies may also request identity verification before dispensing medication.

9. DATA PROTECTION

Personal data is processed in accordance with:

  • the General Data Protection Regulation (EU) 2016/679 (GDPR);

  • Portuguese Law No. 58/2019;

  • applicable healthcare confidentiality obligations;

  • the pH7 Global Privacy Policy.

Special category health information is processed only where a lawful basis exists under applicable legislation.

Where personal data is transferred internationally, appropriate safeguards, including Standard Contractual Clauses where applicable, will be implemented in accordance with GDPR.

10. PAYMENTS

Consultation fees are processed securely through authorised payment providers.

Payment processing is performed solely for facilitating Platform Services.

Healthcare Professionals and Pharmacies remain independently responsible for their own taxation, accounting and regulatory obligations.

11. COMPLAINTS

Clinical complaints should initially be directed to the treating Healthcare Professional responsible for the Consultation.

Complaints relating to medicines or pharmacy services should be directed to the dispensing Pharmacy.

Platform-related complaints may be submitted to:

legal@ph7.health

Patients may also submit complaints to the appropriate Portuguese regulatory authority where applicable.

12. REGULATORY COMPLIANCE

pH7 is committed to operating in accordance with applicable Portuguese and European Union legislation relating to:

  • digital healthcare services;

  • telemedicine;

  • medical confidentiality;

  • medicinal cannabis regulation;

  • prescription medicines;

  • pharmaceutical services;

  • payment processing;

  • cybersecurity;

  • data protection.

Healthcare Professionals and Pharmacies remain independently responsible for compliance with the professional, legal and regulatory obligations applicable to their own practice.

ADDITIONAL PORTUGAL REGULATORY TERMS

The Platform is not intended for emergency medical care. Patients experiencing a medical emergency should immediately contact the appropriate emergency services.

Healthcare Professionals remain responsible for creating and maintaining any clinical records required under applicable law and professional standards.

The Pharmacy independently determines whether a prescription satisfies all legal and professional dispensing requirements and may refuse to dispense where required by law or professional judgement.

pH7 will cooperate with lawful requests made by competent regulatory authorities where required by applicable law.

Nothing in these Terms excludes, restricts or limits any consumer rights that cannot lawfully be excluded under applicable legislation.

pH7 does not use automated decision-making or artificial intelligence to make clinical decisions on behalf of Healthcare Professionals.

Where personal data is transferred internationally, pH7 will implement appropriate safeguards under GDPR and applicable Portuguese data protection legislation.

Where electronic prescribing is permitted under applicable legislation, prescriptions may be transmitted electronically using approved systems.

pH7 applies cybersecurity controls including encryption in transit, encryption at rest, role-based access controls, audit logging and regular security monitoring.

Relevant regulator references include:

  • INFARMED, I.P.;

  • Entidade Reguladora da SaĂşde (ERS);

  • Ordem dos MĂ©dicos; and

  • ComissĂŁo Nacional de Proteção de Dados (CNPD).

13. GOVERNING LAW

This Schedule shall be governed by and construed in accordance with the laws of Portugal.

14. JURISDICTION

Subject to any mandatory consumer rights under applicable law, the courts of the District of Lisbon (Tribunal Judicial da Comarca de Lisboa) shall have exclusive jurisdiction to determine any dispute arising from or relating to this Schedule.

SCHEDULE C – AUSTRALIA

This Australia Schedule forms part of the pH7 Global Terms and Conditions and applies only where Services are provided within Australia.

1. APPLICABILITY

This Schedule applies where:

  • you are located in Australia when using the Platform;

  • your Consultation is provided by an Australian registered Healthcare Professional;

  • your prescription is issued under Australian law;

  • your medication is dispensed by an Australian pharmacy; or

  • the Services are provided by the Australian operating entity.

Where there is any inconsistency between this Schedule and the Global Terms and Conditions, this Schedule shall prevail to the extent required by applicable Australian law.

2. AUSTRALIAN OPERATING ENTITY

Services within Australia are provided by:

Tetrodaxol AUS Pty Ltd

ACN: 698 563 816

Registered Office:

C/- Suite 302

Level 3

191 Clarence Street

Sydney NSW 2000

Australia

Trading as pH7

3. ROLE OF pH7

Within Australia, pH7 operates solely as a digital healthcare technology platform.

pH7:

  • facilitates patient onboarding and identity verification;

  • provides appointment booking functionality;

  • enables secure communication between Patients and Healthcare Professionals;

  • facilitates secure payment processing;

  • facilitates prescription transmission where authorised by the prescriber and Patient;

  • connects Patients with independent Healthcare Professionals and licensed Pharmacies.

pH7 does not:

  • provide medical advice;

  • diagnose medical conditions;

  • prescribe medicines;

  • determine treatment plans;

  • dispense medicines;

  • manufacture medicines;

  • replace emergency medical services.

All clinical responsibility remains solely with the treating Healthcare Professional.

4. HEALTHCARE PROFESSIONALS

Healthcare Professionals using the Platform must:

  • hold current registration with the Australian Health Practitioner Regulation Agency (AHPRA);

  • comply with the standards, codes and guidelines of the Medical Board of Australia;

  • maintain appropriate professional indemnity insurance;

  • comply with all applicable Commonwealth, State and Territory legislation governing medical practice, prescribing and telehealth;

  • remain solely responsible for all clinical decisions, diagnoses, prescriptions and treatment plans.

pH7 does not interfere with the independent clinical judgement of Healthcare Professionals.

5. TELEHEALTH CONSULTATIONS

Telehealth Consultations are conducted in accordance with applicable Australian legislation and professional guidance.

Healthcare Professionals determine whether telehealth is clinically appropriate for each Patient.

A clinician may:

  • request additional medical records;

  • request supporting documentation;

  • request diagnostic investigations;

  • request further identity verification;

  • require an in-person consultation;

  • decline to prescribe where clinically appropriate.

Completion of a Consultation does not guarantee that a prescription or treatment will be issued.

6. PRESCRIBING AND MEDICINAL CANNABIS

Where medicinal cannabis or any prescription medicine is prescribed, the treating Healthcare Professional remains solely responsible for ensuring compliance with all applicable Australian legislation and regulatory requirements, including where applicable:

  • the Therapeutic Goods Act 1989;

  • the Therapeutic Goods Administration (TGA) Special Access Scheme (SAS) and Authorised Prescriber Scheme;

  • relevant State and Territory controlled medicines legislation;

  • applicable guidance issued by the Medical Board of Australia and AHPRA.

pH7 does not influence prescribing decisions and does not determine whether any medicine is clinically appropriate.

7. PHARMACIES

Pharmacies available through the Platform must:

  • be appropriately licensed under Australian law;

  • comply with applicable Commonwealth, State and Territory legislation;

  • independently verify every prescription before dispensing;

  • comply with all applicable requirements relating to Schedule medicines and controlled medicines.

Dispensing decisions remain solely the responsibility of the Pharmacy.

8. PATIENT VERIFICATION

Patients may be required to complete identity verification before:

  • accessing Platform Services;

  • attending Consultations;

  • receiving prescriptions;

  • obtaining Schedule medicines;

  • completing payment transactions; or

  • arranging Pharmacy fulfilment.

Healthcare Professionals may refuse treatment where identity cannot be satisfactorily verified.

Pharmacies may also request additional identification where required by law or professional practice.

9. DATA PROTECTION

Personal information is processed in accordance with:

  • the Privacy Act 1988 (Cth);

  • the Australian Privacy Principles (APPs);

  • the My Health Records Act 2012, where applicable;

  • the pH7 Global Privacy Policy.

Health information is collected, used and disclosed only where authorised by law or with the Patient’s consent.

Where personal information is transferred internationally, appropriate contractual and technical safeguards will be implemented.

10. PAYMENTS

Consultation fees are processed securely through authorised payment providers.

Payment processing is performed solely for facilitating Platform Services.

Healthcare Professionals and Pharmacies remain independently responsible for their own taxation, accounting and regulatory obligations.

11. COMPLAINTS

Clinical complaints should initially be directed to the treating Healthcare Professional responsible for the Consultation.

Complaints relating to medicines or pharmacy services should be directed to the dispensing Pharmacy.

Platform-related complaints may be submitted to:

legal@ph7.health

Patients may also submit complaints to the appropriate Australian regulator where applicable, including AHPRA or the relevant State or Territory Health Complaints Commission.

12. REGULATORY COMPLIANCE

pH7 is committed to operating in accordance with applicable Australian legislation relating to:

  • digital healthcare services;

  • telehealth;

  • prescription medicines;

  • medicinal cannabis;

  • patient confidentiality;

  • privacy and data protection;

  • payment processing;

  • cybersecurity.

Healthcare Professionals and Pharmacies remain independently responsible for compliance with the professional, legal and regulatory obligations applicable to their own practice.

ADDITIONAL AUSTRALIA REGULATORY TERMS

The Platform is not intended for emergency medical care. Patients experiencing a medical emergency should immediately contact the appropriate emergency services.

Healthcare Professionals remain responsible for creating and maintaining any clinical records required under applicable law and professional standards.

The Pharmacy independently determines whether a prescription satisfies all legal and professional dispensing requirements and may refuse to dispense where required by law or professional judgement.

pH7 will cooperate with lawful requests made by competent regulatory authorities where required by applicable law.

Nothing in these Terms excludes, restricts or limits any consumer rights that cannot lawfully be excluded under applicable legislation.

pH7 does not use automated decision-making or artificial intelligence to make clinical decisions on behalf of Healthcare Professionals.

Where personal information is transferred internationally, pH7 will implement contractual and technical safeguards designed to comply with Australian privacy legislation.

Where electronic prescribing is permitted under applicable legislation, prescriptions may be transmitted electronically using approved systems.

pH7 applies cybersecurity controls including encryption in transit, encryption at rest, role-based access controls, audit logging and regular security monitoring.

Relevant regulator references include:

  • Australian Health Practitioner Regulation Agency (AHPRA);

  • Medical Board of Australia;

  • Therapeutic Goods Administration (TGA); and

  • Office of the Australian Information Commissioner (OAIC).

13. GOVERNING LAW

This Schedule shall be governed by and construed in accordance with the laws of New South Wales, Australia, unless mandatory consumer protection legislation requires otherwise.

14. JURISDICTION

Subject to any mandatory consumer rights under applicable law, the courts of New South Wales, Australia shall have exclusive jurisdiction to determine any dispute arising from or relating to this Schedule.