Effective 20th January 2021
Our privacy commitment to you…EpiSwitch Rx is committed to providing you with the best possible customer service experience. We take privacy issues very seriously and we are committed to protecting your information. We will protect your personal information in accordance with unilaterally accepted Privacy Principles. These principles govern how we can collect, use, hold and disclose your personal information, as well as ensuring the quality and security of your personal information.
California Residents: For information relating to California residents, please see the below California Residents Section.
DATA WE COLLECT AND USE
We collect personal data you choose to provide, e.g., through registrations, applications and surveys, and in connection with your inquiries and purchases. For example, you may choose to provide your name, contact information, health, insurance and/or financial information in connection with a promotion or a patient assistance or support program. Healthcare providers may choose to provide information relating to their specialties and professional affiliations.
In addition, we may gather information about you automatically through your use of the Site, e.g., your IP address and how you navigate our Site.
From time to time, we may use or augment the personal data we have about you with information obtained from other sources, such as public databases, social media platforms and other third parties. For example, we may use such third party information to confirm contact or financial information, to verify licensure of healthcare professionals or to better understand your interests by associating demographic information with the information you have provided.
In order to provide our product or service, now and in the future, we may collect and hold additional personal information about you. This could include transaction information or making a record of queries or requests for further information. We may also keep an auditable historic record of your request to access, our granting of access, your use and interaction with information stored as part of a password protected area within our site. The information we hold could be used to legally prove that you were introduced to the information in our password protected area through the use of our website, product and or service. The information that we seek to collect about you will depend on the products or services that we provide. If you do not allow us to collect all of the information we request, we may not be able to deliver all of those services effectively. We will maintain this information in strict confidence and will only use this information in connection with the natural course of our business or in compliance with the law & Privacy Principles. Some sections of this website may also allow you to contact us by email or otherwise volunteer information about yourself, such as your name, email address and your preferred means of communication. In addition to the purposes outlined above, this information may be used and disclosed for the purposes of carrying out or responding to your requests and other purposes outlined at the time you provide the information.
We collect most personal information directly from you. For example we will collect your personal information when you apply for or use a product or service or talk to us in person or on the phone. We also collect information from you electronically. For instance, when you visit our website or whenever you apply for or access our products and services electronically. We may also gather information about you from other companies, publicly available sources of information, your representatives (including your legal adviser, financial advisor, trustee or other entity, your employer or other organizations who provide products or services to you), commercial information service providers, companies that provide fraud prevention and or credit reports etc.
WE MAY COLLECT PERSONAL INFORMATION ELECTRONICALLY
We will collect information from you electronically, for instance through internet browsing, mobile or tablet applications. Each time you visit our website we collect information about your use of the website, which may include the following: The date and time of visits, which pages are viewed, how users navigate through the site and interact with pages (including fields completed in forms and applications completed), location information about users, information about devices used to visit our website and IP address. We may use technology called cookies when you visit our site. Cookies are small data files that a website is able to place on a user's hard drive to record aspects of that user's experience of the website. These files allow the user to move quickly and easily around our site. They are used to identify a user's session, providing information that the system uses to efficiently manage your use of the site. We do not link this information to user's personal details.
THIRD PARTY SERVICES
When you click on links on our website, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements. Occasionally, at our discretion, we may include, offer or provide information on third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
AGE OF CONSENT
By using this site, you represent that you are a minimum of 18 years old or are at least the age of majority in your state or province.
CHILDREN'S ONLINE PRIVACY PROTECTION ACT COMPLIANCE
We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 18 years of age. Our website, products and services are all directed to people who are at least 18 years old or older.
HOW WE USE PERSONAL DATA
We may use your personal data in the following ways:
TO SERVE YOU
We use your personal data to:
Operate our business;
Deliver our products and services;
Process, complete and fulfil your requested transactions;
Provide customer service and respond to requests or inquiries;
Communicate with you;
Tailor our marketing programs and campaigns; and
Provide you with newsletters, articles, alerts, announcements, invitations, and other information about products, brands, health topics and disease states.
Generally we may disclose personal information to organizations that help us with our business. These may include; Our agents, contractors and external service providers, authorized representatives, payment systems operators (for example, merchants receiving card payments), other organizations who jointly with us provide products or services to you, debt collectors, our financial advisors, legal advisers or auditors, your representatives (including your legal adviser, accountant, financial advisor, trustee or attorney, fraud bureaus or other organizations to identify, investigate or prevent fraud or other misconduct or material loss to our business, external dispute resolution schemes and regulatory bodies, government agencies and law enforcement bodies in any jurisdiction or other companies we may occasionally hire to provide services on our behalf, including handling customer support enquiries, processing transactions or providing third party services. Those companies will be permitted to obtain only the personal information they need to deliver the service. We take reasonable steps to ensure that these organizations are bound by confidentiality and privacy obligations in relation to the protection of your personal information. We may also disclose your personal information to others outside of EpiSwitch Rx where we are required or authorized by law or where we have a public duty to do so or we are otherwise permitted to disclose the information under the Privacy Act or if you violate our Terms of Service.
The main reason we collect, hold, use and disclose personal information is to provide you with products and services. We will use our best endeavor to use your personal information you provide only for purposes consistent with the reason you provided it (primary purpose) or for a directly related purpose (secondary purpose). This might include: Checking whether you are eligible for the product or service, Assisting you with interacting with our products or service, Providing the product or service, Managing the product or service. We may also use your information to comply with legislative or regulatory requirements in any jurisdiction, prevent fraud, crime or other activity that may cause harm or material loss to us in relation to our products or services and to help us run our business. We may also use your information to tell you about products or services we think may interest you. We do not share your personal information with other organizations unless you give us your express consent, or where sharing is otherwise required or permitted by law, or where this is necessary on a temporary basis to enable our contractors to perform specific functions. If we do disclose personal information to third parties, we will do so in accordance with the primary purpose or a directly related purpose. The types of third parties we may disclose your personal information to include our service providers such as: Specialist information technology companies, mail holders, or other contractors. For each visitor to reach the site, we expressively collect the following non-personally identifiable information, including but not limited to browser type, version and language, operating system, pages viewed while browsing the Site, page access times and referring website address. This collected information is used solely internally for the purpose of gauging visitor traffic, trends and delivering personalized content to you while you are at this Site. From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future we will use for these new purposes only, data collected from the time of the policy change forward will adhere to our updated practices.
TO CONNECT YOU WITH THIRD PARTIES
We may provide functionality on the Site that will allow you to forward and share certain content with a friend or colleague. If you choose to use sharing functionality to refer someone to our content, products or services, we will use your data and that of the individual you are sharing with to send the content or link you request.
TO VALIDATE YOUR ABILITY TO ACCESS/USE CERTAIN PRODUCTS, SERVICES AND INFORMATION
Some products, services and information we offer may only be suitable for/accessible to individuals meeting certain eligibility or other criteria. In such cases, we may verify that you meet such criteria. For example, certain information relating to our products is only intended for and accessible to licensed healthcare professionals and we may use information we collect directly from you and from outside sources to validate your licensure and eligibility to view such information.
IN ACCORDANCE WITH SPECIAL PROGRAM TERMS
On occasion, We may offer special programs, activities, events or promotions via the Site (“Special Programs”) that have specific terms, privacy notices and/or consent forms that explain how any personal data you provide will be processed in connection with the Special Program. We strongly suggest you review the terms applicable to the Special Program before participating.
TO IMPROVE PRODUCTS AND SERVICES AND PROTECT PATIENTS AND CONSUMERS
We use the information you provide for data analysis, to better understand how our products and services impact you and those you care for, to track and respond to concerns, for fraud prevention and to further develop and improve our products and services. In addition, we use the information you provide to comply with our regulatory monitoring and reporting obligations including those related to adverse events, product complaints and patient safety.
IN AGGREGATED OR DE-IDENTIFIED FORM
We may aggregate and/or de-identify data about visitors to our Site and use it for any purpose, including product and service development and improvement activities.
HOW WE SHARE YOUR PERSONAL DATA
We may share your personal data as follows:
TO COMPLY WITH LAW/PROTECT
We reserve the right to disclose your personal data as required by law, when we believe disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request, or legal process served on us, or to protect the safety, rights, or property of our customers, the public, EpiSwitch or others.
WE MAY DISCLOSE PERSONAL INFORMATION REGARDLESS OF GEOGRAPHY
As our product, service, website and the very nature of our business entails interaction with participants from around the world we do not limit the geography of where a recipient, to whom we may disclose personal information, may be located. The countries, territories or geographies where we disclose your information will depend on the details of the products or services we provide.
CATEGORIES OF PERSONAL DATA THAT WE COLLECT AND DISCLOSE
Listed below are the categories of personal data about California residents that we: (1) may collect and (2) may disclose for a business purpose.
For more information about how we disclose your personal data, refer to the How We Share Your Personal Data Section above.
CATEGORIES OF PERSONAL DATA WE COLLECT AND DISCLOSE
A. NAME, CONTACT INFORMATION AND IDENTIFIERS: Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, user name, social security number, tax ID, driver’s license number, passport number, or other similar identifiers.
B. CUSTOMER AND OTHER RECORDS: Paper and electronic customer records containing personal data, such as name, signature, physical characteristics or description, address, telephone number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
C. PROTECTED CLASSIFICATIONS: Characteristics of protected classifications under California or federal law such as race, colour, sex, gender, age, national origin, disability, and citizenship status.
D. PURCHASE HISTORY AND TENDENCIES: Commercial information, including records of products or services considered, purchased or owned.
E. BIOMETRIC INFORMATION: Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, fingerprint, diagnostic or lab results, imagery of the face from which an identifier template can be extracted, and sleep, health, or exercise data that contain identifying information.
F. USAGE DATA: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement.
G. GEOLOCATION DATA: Precise geographic location information about a particular individual or device.
H. AUDIO/VISUAL: Audio, electronic, or visual recordings, or similar information.
I. EMPLOYMENT HISTORY: Professional or employment-related information.
J. EDUCATION INFORMATION: Information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
K. PROFILES AND INFERENCES: Inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.
APPLICABLE CALIFORNIA RESIDENTS
A. Health care providers; investigators; patients; clinical trial participants; caregivers; website visitors
B. Patients; clinical trial participants; caregivers
C. Health care providers; investigators; patients; clinical trial participants; caregivers
D. Health care providers; investigators; patients; caregivers
E. Clinical trial participants; patients
F. Health care providers; investigators; patients; caregivers; website visitors
G. Health care providers; patients; caregivers; website visitors
H. Health care providers; investigators; patients; clinical trial participants; caregivers
I. Investigators; caregivers
J. Health care providers; investigators; clinical trial participants; caregivers
K. Health care providers; patients; clinical trial participants; caregivers; website visitors
DISCLOSED TO WHICH CATEGORIES OF THIRD PARTIES
A. Service providers
B. Service providers
C. Service providers
D. Service providers
E. Service providers
F. Service providers
G. Service providers
H. Service providers
I. Service providers
J. Service Providers
K. Service Providers
Also as described above in the How We Use Personal Data Section we may use this personal data to serve you; to connect you with third parties; to validate your ability to access and/or use certain products, services and information; to improve products and services; to protect patients and consumers; and in accordance with special program terms.
Protecting personal information
We make every reasonable effort to protect personal information from loss and misuse, and from unauthorized access, modification or disclosure, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed, however; there are risks in transmitting information across the Internet. While we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us online and individuals do so at their own risk. We take all reasonable steps to ensure that sensitive information that we collect is only accessible by authorized persons.
Subject to certain exceptions, California residents have the right to make the following requests, at no charge:
Copy: You may request, up to twice every 12 months, a copy of the specific pieces of personal data that we have collected, used or disclosed about you in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows you to transmit this information to another entity without hindrance.
Deletion: You may request deletion of your personal data that we have collected about you.
Know: You may request, up to twice every 12 months, that we provide you certain information about how we have handled your personal data in the prior 12 months, including the:
categories of personal data collected;
categories of sources of personal data;
business and/or commercial purposes for collecting your personal data;
categories of third parties/with whom we have disclosed or shared your personal data; and
categories of personal data that we have disclosed or shared with a third party for a business purpose.
You have the right to be free from unlawful discrimination for exercising your rights under the California Consumer Privacy Act.
Submitting Requests. You may submit requests to delete, access a copy and/or know personal data we have collected about you by contacting us at: firstname.lastname@example.org
You will be asked to provide certain personal information when submitting your request including your relationship with EpiSwitch Rx, first and last name, email address, telephone number and postal address in order for us to determine if your information is in our systems.
We will further verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request additional personal information from you, such as your date of birth or government identifier, in order to protect against fraudulent or spoofed requests. If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide us with proof that you have been authorized by the California resident on whose behalf you are making the request, which may include signed permission provided by such California resident.
Please contact us according to the Contact Us Section below, if you have any questions regarding this Section for California residents.
You may send any privacy-related questions to email@example.com
If you have any complaints regarding the processing of your personal data by or on behalf of EpiSwitch Rx, we hope you will contact us in order to allow us to address your concern.
If you would like to request to review, correct, or update personal data that you have provided to us, you may contact us as indicated in the Contact Us section. We will respond to your request consistent with applicable law. Please note that we may need to retain certain personal data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
For information relating to California residents, see the California Residents Section above.
If you would like to exercise any individual rights, please contact us by accessing our webform at www.episwitchrx.com/contact
We will respond to your request consistent with applicable law.
EpiSwitch Rx Inc.
450 Sinclair Street