Privacy Policy

PRIVACY POLICY

Last modified: 1/23/2024

Introduction

ASPN Pharmacies ("Company" or "we") respect your privacy and are committed to protecting it.

This policy describes the types of information we may collect from you through this website (our "Website"), and our interactions with you both online and offline, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

We may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”).

If you are a resident of California, Colorado, Connecticut, Virginia, or Utah, please review the “State-Specific Privacy Information” section below for information on additional privacy rights that may apply to you.

This policy applies to Personal Information we collect:

On this Website.
In email, text, and other electronic messages between you, this Website, and Company.

It does not apply to:

Information collected on third-party websites.
De-identified or anonymized information.
Employee, applicant, or contractor information.
Information that constitutes protected health information (“PHI”) as defined by the Health Insurance Portability and Accountability Act and its subsequent laws and regulations (“HIPAA”), which is subject to our Notice of Privacy Practices (“NPP”).

Please read this policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. By accessing or using this Website, you acknowledge this privacy policy.

Changes to this Policy

This policy may change from time to time. All changes will be effective immediately upon posting to this Website. Material changes will be conspicuously posted on the Website or otherwise communicated to you.

Children’s Personal Information

Our Website is not intended for children under 16 years of age. No one under the age of 16 may access or use the Website. We do not knowingly collect Personal Information from children under 16. If we learn we have collected or received Personal Information from a child under 16 without parental consent, we will make a commercially reasonable effort to delete that Personal Information.

Personal Information We Collect

We collect Personal Information directly from you as well as through automatic data collection technologies.

Information You Provide

We collect several types of Personal Information directly from you. Such Personal Information includes: Information that you provide on our Website. This includes:
- filling out our forms that request personal information;
- providing information at the time of registering for an account on our Website;
- business information, such as contact information;
- registering for events, and
- requesting further services, information, or customer service, such as when you report an issue on the Website.
Records and copies of your correspondence (including email addresses) if you contact us.
Payment information.
Your responses to surveys that we might ask you to complete for research and marketing purposes.
Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
Any Personal Information provided when you contact us by phone, email, or mail.
We may collect Personal Information from other websites and social media platforms. We are active on social media platforms such as Facebook, Instagram, LinkedIn, X (formerly Twitter), and YouTube. Anything you post on such public sites is public information and will not be treated confidentially. We may post (or re-post) on our Website and our social media pages any comments or content that you post on social media platforms. Your use of third-party websites is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website which includes traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may be only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use Personal Information for the following purposes:

To present our Website and its contents to you.
For administrative purposes, such as managing accounts.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account and respond to your inquiries about our services.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website, this Policy or our Terms of User or other terms and any products or services you receive or that we offer or provide though our Website.
To provide, improve and create new services.
To send you electronic messages and personalized emails pertaining to the transactions and services we are providing to you.
To statistically analyze trends and user behavior and activity including how frequently areas of the Website are visited and being used.
To detect and defend against fraud and other threats to our services and our users.
To identify issues with the services, maintenance and administration of our websites and your account.

To protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our website, or to other users of the Website.

In any other way as described or obvious when you provide the Personal Information.
For any other purpose with your consent.

Disclosure of Your Personal Information

We may disclose Personal Information that we collect, or you provide as described in this privacy policy with the following categories of third parties:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Asembia's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Company is among the assets transferred.
To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information below.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us or obvious when you provide the Personal Information.
With your consent.

We may also disclose your Personal Information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Asembia and its affiliates, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Personal Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Disclosure of Your Personal Information for Third-Party Advertising. We do not disclose your Personal Information to Third Party Advertisers, unless you have provided explicit consent to do so.

Accessing and Correcting Your Personal Information

If you have an account with us, you may also review and change your Personal Information by logging into the Website and visiting your account profile page.

We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

State-Specific Privacy Information

Please review the applicable state section below if you are a resident of that state for information that may apply to you.

California

Under the CCPA, California residents have the right to receive certain disclosures regarding our information practices related to “Personal Information,” as defined under the CCPA. To the extent you are a resident of California, and we collect Personal Information subject to CCPA, the following applies:

Categories of Personal Information

In the last twelve (12) months, we have collected the following categories of Personal Information under CCPA:

Identifiers consisting of: real name, alias, postal address, unique personal identifier, online identifier, internet protocol address (“IP Address”), email address, account name, social security number, driver’s license number, or other similar identifiers.
Consumer information under Cal. Civ. Code 1798.80(e) consisting of: bank account number, credit card number, debit card number, signature, physical characteristics or description, telephone number, state identification number, health insurance number, insurance policy number, and any other financial information or medical information.
Protected Classifications consisting of: Age race, color, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Commercial Information consisting of: Commercial information, including records of customer billing information, products or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric Information consisting of: genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information.
Internet Activity consisting of: information regarding a consumer’s interaction with an internet website application, or advertisement.
Geolocation Data: GPS geolocation, IP address, and other data from sensors on or around your device, depending in part on your device and account.
Sensory Data: Audio, electronic, visual, or similar information.
Employment Information: Professional or employment-related information

Sensitive Personal Information: social security number, driver’s license, state identification card, precise geolocation, consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; consumer’s racial or ethnic origin; or contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; personal information about consumer’s health, sex life, or sexual orientation.

Categories of Sources from which Personal Information is Collected

We collect Personal Information from the categories listed in the “Personal Information We Collect” section above.

Purposes for Collecting Personal Information

We collect Personal Information for the purposes listed in the “How We Use Your Information” section above.

Disclosures to Third Parties

In the last 12 months, we have disclosed all categories of the Personal Information to the categories of third parties identified in the section titled “Disclosure of Your Personal Information” :

Categories of Personal Information Sold or Shared

The CCPA defines a "sale" as disclosing or making available to a third-party Personal Information in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available Personal Information to a third party for purposes of cross- context behavioral advertising. While we do not disclose Personal Information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA) identifiers and internet and electronic network activity information to third parties. Such categories of third parties may include third party analytics providers. We do so for the purposes of improving and evaluating our services and better reach customers and prospective customers with a better user experience.

We do not have actual knowledge that we sell or share any Personal Information about individuals that are under sixteen (16) years old.

Sensitive Personal Information

Company may use or disclose Sensitive Personal Information for purposes that, under applicable law, require us to offer you a “Right to Limit” the use or disclosure of sensitive personal information. You may ask Company to only use your sensitive personal information for limited purposes, such as providing you with the services you requested by contacting Company at ComplianceReview@asembia.com.

Retention

We will retain Personal Information for a minimum of ten (10) years from the date of the documentations’ creation, or the date when it was last in effect, whichever is later.

California’s “Do-Not-Track” Requirement. We currently do not respond to “do not track” requests.

California Privacy Rights

To the extent you are a resident of California, you may have the following rights to your Personal Information:

Right to Access: With respect to the Personal Information we have collected about you in the prior 12 months, you have the right to request from us (up to twice per year and subject to certain exemptions): (i) categories of Personal Information about you we have collected; (ii) the categories of sources from which we have collected that Personal Information; (iii) our business or commercial purposes for collecting, selling, or disclosing that Personal Information; (iv) the categories of third parties to whom we have disclosed that Personal Information; and (v) a copy of the specific pieces of your Personal Information we have collected.
Right to Correct: You have the right to request that we correct inaccuracies in your Personal Information.
Right to Delete: Subject to certain conditions and exceptions, you may have the right to request deletion of Personal Information that we have collected about you.
Right to Non-Discrimination: We will not discriminate against you for exercising any of the rights described in this section. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this section.
Authorized Agent: You may designate someone as an authorized agent to submit requests and act on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf.

To make a request for the rights described above, please contact us at ComplianceReview@asembia.com, by telephone at (973) 564-8004, or at Asembia Compliance, 200 Park Ave, Suite 300, Florham Park, NJ 07932. Please indicate you are making a request pursuant to your “California Privacy Rights.” You must provide us with the following information: (1) first and last name; (2) email address; and (3) physical address. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your request or, where necessary, to process your request. If we are unable to adequately verify a request, we will notify the requestor.

Your Right to Opt-Out of the Sale of Personal Information

California residents may direct us not to Sell their Personal Information at any time (this is your right to “opt-out”). You may submit your opt-out request via email to compliancereview@asembia.com

Colorado

We have collected or processed the categories of Personal Information listed in the “Personal Information We Collect” section above.

Purposes for Collecting Personal Information

We collect Personal Information for the purposes listed in the “How We Use Your Information” section above.

Categories of Personal Data Shared with Third Parties and Categories of Third Parties

We share all categories of Personal Data with the categories of third parties in the “Disclosure of Your Personal Information” section above.

Colorado Privacy Rights

Under the CPA, Colorado residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under the CPA, as well as certain rights with respect to our processing of such Personal Data. To the extent you are a resident of Colorado, and we collect Personal Data subject to applicable Colorado law, the following applies.

Right to Access: You have the right to confirm whether or not we are processing your Personal Data and to access such Personal Data.
Right to Correction: You have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
Right to Deletion: You have the right to delete the Personal Data provided to us by you.
Right to Data Portability: When exercising your Right to Access, you have the right to obtain the Personal Data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Data to another entity without hindrance. You may exercise this right no more than two times per calendar year.
Right to Opt-Out of Sale, Targeted Advertising, and Profiling: Colorado residents have the right to opt out of the processing of Personal Data for the purposes of targeted advertising. To opt out of targeted advertising, please contact us at compliancereview@asembia.com.
Authorized Agent: You may authorize another person to act on your behalf to opt out of the processing of your Personal Data.

If any of the rights described in the section apply to you, you may make a request by contacting us at ComplianceReview@asembia.com. Please indicate that you are making a request pursuant to your “Colorado Privacy Rights” and provide us with the following information: (1) first and last name; (2) email address; (3) physical address; and (4) date of birth. We will take steps to verify your request by matching the information provided by you with the information we have in our records.

Right to Appeal: If we decline to take action regarding your request, you have the right to appeal. We will notify you providing our reasons and instructions for how you can appeal the decision. No later than sixty days after receipt of an appeal, we shall inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, we will provide a way for you contact the Attorney General to submit a complaint.

Connecticut

We have collected or processed the categories of Personal Information listed in the “Personal Information We Collect” section above.

Purposes for Collecting Personal Information

We collect Personal Information for the purposes listed in the “How We Use Your Information” section above.

We share all following categories of Personal Data with the categories of third parties in the “Disclosure of Your Personal Information” section above.

Connecticut Privacy Rights

Under the CTDPA, Connecticut residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under the CTDPA, as well as certain rights with respect to our processing of such Personal Data. To the extent you are a Connecticut resident, and we collect Personal Data subject to applicable Connecticut law, the following applies.

Right to Access: You may have the right to confirm whether or not we are processing your Personal Data and to access such Personal Data.
Right to Correction: You may have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
Right to Deletion: You may have the right to delete the Personal Data provided to us by you.
Right to Data Portability: You may have the right to obtain a copy of the Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Data to another controller without hindrance, where the processing is carried out by automated means.
Right to Opt-Out of Sale, Targeted Advertising, and Profiling: Connecticut residents have the right to opt out of the processing of Personal Data for the purposes of targeted advertising. To opt out of targeted advertising, please contact us via email at compliancereview@asembia.com.
Right to Appeal: If we decline to take action regarding your request, you have the right to appeal. We will notify you providing our reasons and instructions for how you can appeal the decision. No later than sixty days after receipt of an appeal, we shall inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, we will provide a way for you contact the Attorney General to submit a complaint.
Authorized Agent. You may authorize another person to act on your behalf to opt out of the processing of your Personal Data.

If any of the rights described in the section apply to you, you may make a request by contacting us at ComplianceReview@asembia.com. Please indicate that you are making a request pursuant to your “Connecticut Privacy Rights” and provide us with the following information: (1) first and last name; (2) email address; and (3) physical address. We will take steps to verify your request by matching the information provided by you with the information we have in our records.

Virginia

We have collected or processed the categories of Personal Information listed in the “Personal Information We Collect” section above.

Purposes for Collecting Personal Information

We collect Personal Information for the purposes listed in the “How We Use Your Information” section above.

We share all following categories of Personal Data with the categories of third parties in the “Disclosure of Your Personal Information” section above.

Virginia Privacy Rights

Under the VCDPA, Virginia residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under the VCDPA, as well as certain rights with respect to our processing of such Personal Data. To the extent you are a resident of Virginia and we collect Personal Data subject to applicable Virginia law, the following applies.

Right to Access: To confirm whether or not we are processing your Personal Data and to access such Personal Data.
Right of Portability: You may have the right to obtain a copy of the Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Data to another controller or business where the processing is carried out by automated means.
Right to Correction: You may have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
Right to Deletion: You may have the right to delete Personal Data provided by or obtained about you.
Right to Opt-Out of Sale: Under the VCDPA, a “sale” includes disclosing or making available Personal Information to a third party in exchange for money. We do not “sell” Personal Information under this definition.
Right to Opt-Out of Targeted Ads and Profiling: You may have the right to opt out of the processing of your Personal Data by us for purposes of targeted advertising. To opt out of targeted advertising, please contact us via email at compliancereview@asembia.com.
Right to Appeal: If we decline to take action regarding your request, you have the right to appeal. We will notify you providing our reasons and instructions for how you can appeal the decision. If the appeal is denied, we will provide a way for you contact the Attorney General to submit a complaint.

If any of the rights described in the section apply to you, you may make a request by contacting us at ComplianceReview@asembia.com. Please indicate that you are making a request pursuant to your “Virginia Privacy Rights” and provide us with the following information: (1) first and last name; (2) email address; and (3) physical address.. We will take steps to verify your request by matching the information provided by you with the information we have in our records.

Utah

We have collected or processed the categories of Personal Information listed in the “Personal Information We Collect” section above.

Purposes for Collecting Personal Information

We collect Personal Information for the purposes listed in the “How We Use Your Information” section above.

We share all following categories of Personal Data with the categories of third parties in the “Disclosure of Your Personal Information” section above.

Utah Privacy Rights

Under the Utah Consumer Privacy Act (“UCPA”), Utah residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under UCPA, as well as certain rights with respect to our processing of such Personal Data. To the extent you are a resident of Utah, and we collect Personal Data subject to applicable Utah law, the following applies.

Right to Access: You may have the right to confirm whether or not we are processing your Personal Data and to access such Personal Data.
Right to Correction: You may have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
Right to Deletion: You may have the right to delete the Personal Data provided to us by you.
Right to Data Portability: You may have the right to obtain a copy of the Personal Data that you previously provided to us in a portable and, to the extent technically feasible, is portable, and to the extent practicable, is in a readily usable format that allows you to transmit your Personal Data to another controller without hindrance, where the processing is carried out by automated means.
Right to Opt-Out of Sale and Targeted Advertising: Utah residents have the right to opt out of the processing of Personal Data for the purposes of targeted advertising, and 2) the sale of Personal Data. We do not “sell” Personal Information under Utah law.

If any of the rights described in the section apply to you, you may make a request by contacting us at ComplianceReview@asembia.com. Please indicate that you are making a request pursuant to your “Utah Privacy Rights” and provide us with the following information: (1) first and last name; (2) email address; (3) physical address; and (4) date of birth. We will take steps to verify your request by matching the information provided by you with the information we have in our records.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All transactions and submitted information will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Access Outside the United States

If you access the Website from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by the in other jurisdictions.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

200 Park Avenue

Suite 300

Florham Park, NJ 07932

Attn. Compliance Department

(973) 564-8004

ComplianceReview@asembia.com