The website and associated domains and sub-domains and the mobile application and communication platform related thereto or that you downloaded or accessed in connection with this Privacy Policy (the “Products”) are provided by Grand Specialty Pharmacy, (collectively, “us,” “we,” or “our”).  We respect your privacy and created this Privacy Policy to let you know what information we collect when you access and/or use our Products, or create an account via our Products, and how we use it, as well as our information sharing and protection practices.

This Privacy Policy applies to information we collect:

• through the Products; and
• in email, text, voice or other electronic communications between you and the Products.

This Privacy Policy does not apply to information collected by:

• us offline or through any other means; or
• third parties, including through any application or content (including advertising) that may link to or be accessible from or on the Products.

Please read this Privacy Policy carefully and save it. If you do not agree with it, you should not access and/or use the Products. By using the Products or by submitting electronic communications to us through the Products, or accepting the terms of use, or similar agreement, associated with such Product (“Terms of Use”), or by clicking to accept or agree to this Privacy Policy when this option is made available to you, you consent to the practices prescribed in this Privacy Policy.

What information do we collect?

We collect several types of information from and about users of the Products, including:

• Information that may be used to personally identify or contact an individual, including your first name, last name, date of birth, email address, physical address, and telephone number (“Personal Information”).
• Information relating to your present or future health or condition, the provision of health care to you, or payment for the provision of health care to you, including, your medication information (such as prescription number, medication name, dosage, refill dates, refill reminder dates) and diagnosis information (“PHI” and together with Personal Information, “Sensitive Information”).
• Information about your geographic location from you or your device, including your country, region, city, zip code, street address, time zone, latitude, longitude, velocity, bearing, altitude and horizontal position representation information (“Geo-Location Information”).
• Technical data and related information, such as information about your device, internet connection, system and application software, peripherals and other data related to your interactions with the Products (“Technical Information”).
• Metadata and other information associated with other files stored on your device, such as camera images and photos (“Metadata”).
• Information from your web browser about your activities over time and across third-party products, applications or other online services (“Online Tracking Information”).

How do we collect information?

We Collect Information That You Provide to Us. When you complete a transaction via our Products or otherwise fill out any forms located in/on the Products, or contact us electronically, we may collect the information you provide to us. This information may include your Sensitive Information. It is always your choice whether or not to provide Sensitive Information; however, if you choose not to provide requested Personal Information, you may not be able to use certain features of the Products.

We Collect Information Automatically. We may automatically collect information through cookies, flash cookies, web beacons and log files.  The information we collect from these technologies may include your IP address, device ID, browser information, the page you request Geo-Location Information, Technical Information, Metadata and Online Tracking Information. We do not consider this information to be Personal Information. We do not automatically collect Sensitive Information, but we may tie automatically collected information to your Sensitive Information.

How do we use your information?

We may use your information that we collect, including your Sensitive Information, to:

• fulfill the purpose for which you provided it, such as providing you with information, product, or services that you request from us;
• provide support and other services to you related to the Products;
• improve, market or promote our, or Pharmacy’s, products and services;
• compile, synthesize, generate and analyze anonymous usage and other aggregated statistics and information;
• notify you—including via SMS messages and mobile application push notifications—about your prescriptions (such as that Pharmacy has received your request) and about Product upgrades, special offers, updated information and other new products and services offered by Pharmacy or its third party partners;
• make product and service recommendations to you, including manufacturer savings programs and health improvement programs focused on gaps in care; and
• display advertisements, including advertisements from third parties.

We may also use your information for any other purpose we may describe when we collect your information or to which you otherwise consent.

Who do we share your information with?

We may disclose information that is not Sensitive Information without restriction for any lawful purpose.

We may disclose your Sensitive Information that we collect as described in this Privacy Policy to:

• our affiliates and subsidiaries;
• our agents, vendors, contractors, doctors, health insurance companies (together, “Partners”) who are required to keep the Information confidential, and only (i) to fulfill the purpose for which you provided such Sensitive Information (such as disclosing your full name, address, and medical information to Pharmacy so that Pharmacy may fill, or refill, your prescription), or (ii) to support our provision of Products;
• another organization as part of a transaction or potential transaction where we merge with another organization, file for bankruptcy, or sell our assets or capital stock.
• comply with legal process, law or regulation, or to comply with a governmental or regulatory request;
• protect and defend our, or Pharmacy’s, or our Partner’s, rights or property;
• enforce the Terms of Use and other agreements; and
• act in urgent circumstances to protect the personal safety of users of the Products or the public.

We may also use your Sensitive Information for any other purpose with your consent.

HIPAA

Pharmacy, to the extent it is a “covered entity” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) has its own privacy and security obligations with respect to your PHI. We encourage you to contact Pharmacy regarding their privacy and security practices (for more information regarding your rights under HIPAA, see http://www.hhs.gov/ocr/privacy).

To the extent we are a “business associate” of Pharmacy under HIPAA, we have agreements in place with Pharmacy requiring us to only use and disclose your PHI as Pharmacy is permitted to under HIPAA. This Privacy Policy and the privacy and security practices described in this Privacy Policy are designed to comply with these agreements. As such, among other obligations, we will:

• use reasonable and appropriate safeguards to keep your PHI that we collect private and confidential;
• alert you in accordance with the guidelines set forth under HIPAA if we are made aware of any unauthorized access to your PHI that we have collected; and
• provide you access in a reasonable time and manner to your PHI we have collected and make any reasonably requested amendment thereto.

Grand Specialty Pharmacy. may de-identify Personal Health Information pursuant to the Health Insurance Portability and Accountability Act (“HIPAA”) and aggregate patient’s de-identified information with other Grand Specialty Pharmacy patient information, and use such aggregated information for population based research activities and analytics; Treatment, payment, enrollment, or eligibility for benefits are not conditioned upon patient reviewing the privacy policy; when information is used or disclosed, it may be subject to re-disclosure and may no longer be protected by state or federal privacy regulations.

Acknowledgement regarding SMS messages and push notifications.

To the extent the Products enables you to send or receive SMS messages, the standard text messaging rates or other carrier charges may apply to such use.  Further, to the extent the Products has push notification capability, by downloading such Product and clicking to allow push notifications, YOU CONSENT TO RECEIVE COMMUNICATIONS, INCLUDING COMMERCIAL COMMUNICATIONS FROM OR ON BEHALF OF US, PHARMACY AND PARTNERS.

Security of your Sensitive Information.

We maintain physical, electronic, and procedural safeguards designed to protect your Sensitive Information. These safeguards include storing your Sensitive Information on our secure servers behind firewalls and using encryption technology. Despite the actions and precautions we take, no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of your Sensitive Information and you acknowledge and agree that you transmit it to us at your own risk. However, as noted above, we will alert you in accordance with the guidelines set forth under HIPAA if we are made aware of any unauthorized access to your PHI that we have collected.

Third party products, services and technologies.

We may provide links to third-party products on the Products or in other communications to you. These links may appear as a specific domain name or URL or may be activated by clicking on an advertisement or other icon or graphic. Please be aware that other products and services, including the products of third parties that you connect with through the Products, may collect personally identifiable information about you. We cannot control and are not responsible for the information collection practices of any third-party products, services or applications. We encourage you to carefully review their terms of use, privacy policies, and any other legal notifications before using or providing information through such products, services or applications.

Further, the Products may employ third party technologies that require you to accept such third party’s terms. This Privacy Policy does not cover the information practices of those third-party technologies.

Children’s and dependent’s privacy.

While the Products are not intended for use by children under the age of 13, certain care givers may use these Products for the care of children under the age of 13.  We apply the same rigorous privacy policies set forth in the Health Insurance Portability and Accountability Act of 1996 to children’s information. Additionally, when you submit Sensitive Information, on behalf of your dependents or patients, you warrant that you have the express permission of such person to do so. If you do not have permission to do so, you should not submit such Sensitive Information as you may be violating HIPAA.

Information Choices and Changes

We may need to communicate with you about the Products, and we would like to make certain commercial offers available to you from time to time. As such, by signing up for our newsletter or by creating an account on the Products, you consent to receive commercial messages (whether by phone, email, text or push notifications) from us or our third party partners, and acknowledge and agree that your primary phone numbers and email addresses and other information may be used for the purpose of initiating commercial messages.  We will allow you to opt-out of receiving commercial messages, but in order to stop receiving any messages from us whatsoever (including administrative messages regarding the Products), you will need to terminate your account.

Depending on your browser, you may be able to remove and reject cookies from our Products by changing your browser settings. The default setting of many browsers is set to accept cookies until you change your settings. Please note that if you disable or refuse cookies, certain features of the Products may become inaccessible or may not function properly.

Additionally, your web browser may allow you to opt-out of our collection of Online Tracking Information by selecting a “do not track” (or similar) setting. However, we do not currently have processes to address those settings or other “do not track” requests, and consequently, cannot guarantee that we will honor such requests. If you do not want us to collect this information, do not use the Products.

Changes to this privacy policy.

This is our entire Privacy Policy and it replaces any earlier version. We may change this Privacy Policy by posting a new version on the Products, and it is your responsibility to review this Privacy Policy periodically. If we make material changes to our practices regarding the collection, use and sharing of your Personal Information, we will notify you via e-mail to the email address you provide to us and/or through a notice on the Products.

When we do change the Privacy Policy, we will also revise the “revised” date. Your continued use of the Products after such date constitutes your agreement to this Privacy Policy and any updates.

Information you voluntarily disclose.

Please keep in mind that whenever you voluntarily disclose Information through any public-facing features of the Products (for example, via public forums), that Information can be collected and used by others. You submit this Information at your own risk.  We are not responsible for the security or privacy of any Information you choose to submit in connection with these public features.