Last Updated: September, 2022
PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AS WELL AS YOUR CHOICES AND RIGHTS. IF YOU DO NOT AGREE WITH THE TERMS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE.
THE SITE IS INTENDED FOR USERS LOCATED IN THE UNITED STATES, AND IT IS NOT INTENDED FOR USERS LOCATED IN OTHER COUNTRIES, INCLUDING THE EUROPEAN UNION AND THE EUROPEAN ECONOMIC AREA.
CPESN USA, LLC (also referred to herein as “we,” “us,” and “our”) is committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat the data we collect and process
This Policy does not apply if we are providing services for a “Covered Entity” (for example, a health care provider) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). In those situations, we act as a “Business Associate,” and we use and disclose Protected Health Information (“PHI”) only as permitted or required under applicable law and our business associate agreements. The Covered Entity’s notice of privacy practices describes and controls how we use and disclose PHI.
WHAT PERSONAL INFORMATION DO WE COLLECT
What Personal Information Do We Collect? We may collect the personal information described below:
|Contact Information||When you visit our Site or contact us, we may receive your name, address, and email address.|
|If you use the online registration, in addition to your Contact Information, we will receive the following: NPI, NCPDP Provider ID for your pharmacy, Pharmacy Name, Address, Zip Code|
|Communications and Inquiries||If you contact us, in addition to your Contact Information, we will receive any comments, content, questions, or other information that you choose to provide.|
We may automatically collect information from your browser or device, including the date and time of access; information about what pages you visit and how you navigate the Site; and your location, Internet Protocol (IP) address, device identifier, device type, operating system, and browser type.
Cookies and Similar Technologies
What are first and third-party cookies? A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” cookie). “Session” cookies are temporarily stored on your device and remain there until they expire at the end of your browsing session. “Persistent” cookies remain stored on your device until they expire or are deleted by you. Local shared objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you are visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.
What are “similar technologies”? In addition to cookies, there are other data collection technologies, such as Internet tags, web beacons, pixels (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as you navigate through and interact with a website. For example, web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about your browsing, such as which advertisement, page, or publisher sent you to the receiving website.
Other third-party technologies. Some third parties may use data collection technologies to collect information about you when you browse the Internet. We do not control these third parties’ technologies or how they may be used. If you have questions about targeted content, you should contact the responsible party directly or consult their privacy policies.
Choices about cookies and similar technologies. Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being stored. These settings may affect your enjoyment of the Site’s functionality. Adjusting the cookie settings may not fully delete all of the cookies that have already been created. To delete them, you should review your web browser settings after you have changed your cookie settings. The links below provide additional information about how to disable cookies or manage the cookie settings:
For more information about how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/. You may learn more about internet advertising practices and related consumer resources at https://youradchoices.com/control, https://thenai.org/about-online-advertising/faq, and http://www.networkadvertising.org/choices.
HOW DO WE USE AND SHARE YOUR PERSONAL INFORMATION?
How Do We Use Your Personal Information? We may use your personal information for the purposes described below:
- Operate and improve our business, operations, services, and the Site
- Provide you with services, content, customer service, and functionality
- Improve our services and customer service
- Develop new products and services
- Honor our terms of service and contracts
- Manage our relationship with you and your use of the Site
- Communicate with you and respond to your feedback, requests, questions, or inquiries
- Register you for our email list and send you periodic messages
- Engage with you on social media
- Enable you to share reviews, comments, questions, and answers
- Improve our marketing efforts, including by providing more tailored advertising
- Promote our products and services
- Contact you about other products and services
- Administer a contest, promotion, or survey
- Assess the success of marketing and advertising campaigns
- Ensure the privacy and security of our Site and services
- Maintain our databases and back-ups, including records of our communications with you
- Detect fraud and prevent loss
- Support and improve the Site, including evaluations of functionality and features
- Analyze use of the Site and our services and prepare aggregate traffic information
- Recognize your device and remember your preferences and interactions
- Provide you with a more personal and interactive experience on the Site
- Determine and track user interests, trends, needs, and preferences
- General operational support, including procurement, financial and fiscal management, risk and compliance management, and reporting
- Facilitate corporate mergers, acquisitions, reorganizations, dissolutions, or other transactions
- Obtain and maintain insurance coverage and professional advice
- Accomplish any other purpose (a) that is related or ancillary to any of the purposes described in this Policy, (b) that is described to you when you provide the information or to which you consent, or (c) for which we have a legal basis under law
- Comply with federal, state, or local laws
- Comply with a civil, governmental, or regulatory inquiry, order, subpoena, summons, or process
- Cooperate with law enforcement agencies
- Exercise or defend legal rights or claims
- Create, use, retain, or disclose de-identified or aggregated data
How Do We Share Your Personal Information? We may share your personal information for the purposes described below:
|Affiliates and Networks||We may share your information with our subsidiaries and affiliates and with their respective officers, directors, employees, and agents.|
|Pharmacy and Managing Network Facilitators Listings||We list participating pharmacies' names and addresses on our Site. We also list the names and email addresses for Managing Network Facilitators on our Site.|
|Corporate Transactions||We may disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of our company or some or all of our assets. If our business is acquired by or merged with another company, your information may be transferred to the new owners.|
|Legal Obligations||We may disclose information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share information in order to establish or exercise our legal rights or claims; to defend against a legal claim; and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our contracts or terms.|
|Service Providers and Advisors|| We may share information with our service providers and professional advisors (accountants, attorneys, etc.) that need access to information to provide services on our behalf.
|Third Parties||We may provide information about you to third parties that offer products and services specifically requested by you. We may also ask if you would like for us to share your information with other third parties, but will only do so if you consent.|
|De-Identified and Aggregated Data||We may share with third parties aggregated information and anonymous or de-identified that does not identify any specific individual, such as groupings of demographic data or user preferences.|
HOW LONG DO WE KEEP YOUR INFORMATION?
We will keep your information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to operate our business, and to enforce our agreements.
We may delete your information if we believe it is incomplete, inaccurate, or that our continued storage of it is contrary to our objectives or legal obligations. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it.
We may retain and use anonymous, de-identified, or aggregated information for as long as is permitted under applicable law.
HOW DO WE PROTECT YOUR INFORMATION?
We have adopted security measures that are designed to protect the personal information under our control. From time to time, we review our security procedures and consider new technologies and methods But, no security system is perfect, and no data transmission is 100% secure. Although we strive to protect personal information, we cannot guarantee or warrant the security of any information transmitted to or from the Site. Your use of the Site is at your own risk. We cannot guarantee that your data will remain secure in all circumstances.
If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.
YOUR RIGHTS AND CHOICES
Please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. We honor requests when we are required to do so under applicable law.
Email Preferences. We may send you emails about our Site and services. If you do not want to continue receiving emails from us, you may opt-out by clicking the “unsubscribe” button at the bottom of our emails or by contacting us at [email protected]. Please provide your name and contact information in your request, and we will respond to your request in accordance with applicable law.
Update Your Information. Our goal is to keep your information accurate, current, and complete. If any of the information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Policy. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete personal data that you provide to us
Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.
California. Under California Civil Code § 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us, once each calendar year, information about the information we shared (if any) with other businesses for direct marketing uses. We do not currently share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the California’s “Shine the Light” requirements, and only information regarding covered sharing (if any) will be included in our response. As a part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at [email protected].
Nevada. Nevada residents may submit a verified request to us at [email protected] to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law
THIRD PARTY SITES AND SERVICES
This Policy only applies to the Site. It does not apply to any websites, applications, or services from third parties
The Site may include links to, or content from, third parties. These links are to external resources and third parties that have their own privacy policies. It may not always be clear which links are to external, third-party resources. If you click on a third-party link, you will be redirected away from the Site. You can check the URL to confirm whether you have left the Site. We cannot and do not (1) guarantee the privacy or security practices of third parties or any content provided by third parties; (2) control third parties’ collection or use or your information; or (3) endorse any third-party information, products, services, applications, or websites.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT
Our Site and services are not directed to children under the age of 13, and we do not knowingly collect information from children under the age of 13. No one under the age of 13 may access, browse, or use the Site or provide any information to us. If we learn that we have collected or received personal information from a child under the age of 13 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and to delete it. If you believe we have received information from a child under the age of 13, please contact us using the “Contact Us” details provided below.
For more information about the Children’s Online Privacy Protection Act, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
UPDATES AND CHANGES
We may update this Policy from time to time. If we change this Policy, we will post the revised version on our Site. Any changes, updates, and modifications will be effective immediately upon posting. If we make material changes, we may also notify you through a notice on the Site’s homepage and/or send you an email regarding the updates.
You should read this Policy carefully before using the Site, and you should review it from time to time so that you are aware of its current terms. Your continued use of the Site after the “Last Updated” date will constitute your acceptance of and agreement to any changes and to our collection, use, and sharing of your information according to the then-current Policy. If you do not agree with this Policy, you should not use the Site.
For more information or if you have questions about this Policy, you may contact us using the information below:
CPESN USA, LLC