OURPHARMA PRIVACY POLICY

 Last updated on July, 2021 

Thank you for choosing OurPharma. Protecting your privacy and securing the information we collect is important to us. We work to do that well and to continuously improve our practices. We also want you to understand what information we collect about you, how we collect it and how we use it, and what your rights are with respect to what we do. This policy explains those things. 

Please note that we offer or may offer in the future multiple websites, software, platforms, mobile applications, tools, blogs and other digital and print resources, and other related products, including, but not limited to, our website available at www.ourpharma.net (the “Site”) – plus services and support for the Site. These policies apply to all of our Services, including new or additional Services that we may develop or offer in the future (collectively, all products and all services, the “Services”). 

PLEASE REVIEW THESE POLICIES CAREFULLY. BY USING ANY OF OUR SERVICES IN ANY WAY, INCLUDING ONLY BROWSING THE SITE, YOU ARE AGREEING TO BE BOUND BY OUR POLICIES. Please note that using our Services is your choice. If you do not agree with our policies, you should not use the Services. 

If you have questions or concerns about our policies, please contact us at any of the following: 

  • By email at [email protected]; 
  • By telephone at (833)-290-2654; or 
  • By mail at OurPharma Holdings, LLC, c/o Data Protection Officer, 2512 S. City Lake Road, Fayetteville, AR 72701 

 We may change these policies at any time without prior notice. You can always find the latest version of our Privacy Policy at https://www.ourpharma.net/privacy-policy/. 

1. SUMMARY OF KEY POINTS 

This section summarizes the key points of our privacy policies. Please review the full policy to find additional information and to better understand our policies and your rights related to the same. 

Summary of key points: 

  • What we collect about you, how we collect it, and how we use it depends on your relationship with us; 
  • We collect and use personal information so we can provide and improve our Services; 
  • We do not attempt to monetize your personal information with third parties; and 
  • You have rights and choices that govern how we will handle personal information about you. 

2. WHAT WE COLLECT AND HOW WE COLLECT IT

What information we collect about you and how we collect it depends on our relationship with you. Specifically

  • If your personal information is provided to us by your employer or organization that is our customer (and not you directly), then an explanation of what information we collect about you and how we collect it can be found below in the section 2.A titled “Personal Information from Organizations”; or 
  • If you visit or use our Services under the account of your employer or organization, then an explanation of what information we collect about you and how we collect it can be found below in the section 2.A titled “Personal Information from Organizations”; or
  • If you visit or use our Services as an individual user or through an individual account with us (i.e., not under an account of an employer or organization), then an explanation of what information we collect about you and how we collect it can be found below in the section 2.B titled “Personal Information from Individual Users.”

Please note that our customers are primarily corporate employers and organizations. This means that nearly all of the personal information that we collect and/or use is provided either (1) by employers and organizations on behalf of the individuals associated with those accounts (i.e., not directly from the individuals), or (2) by individuals using our Services under an employer and organization account (i.e., not under an individual account). In other words, we collect very little personal information directly from individual users under individual accounts. 

2.A Personal Information from Organizations 

As stated above, nearly all of the personal information that we collect and store is provided to us either by an employer or organization on behalf of the individuals associated with that company’s or organization’s account, or by individuals visiting and using our Services under an employer or organization account. 

A few examples of how and when this may happen include: 

  • an employer or organization accesses, downloads, logs in, uses, views content on, and/or otherwise interacts with one of our websites, software, platform, or mobile applications; 
  • an employer or organization purchases products via the Services; 
  • an employer or organization submits personal information about individuals on one of our websites, software, platform, or mobile applications by uploading and publishing content, or by sending communications; 
  • an employer or organization interacts with us with respect to account maintenance or service (for example: billing or technical support, and product updates); or 
  • an individual does any of the foregoing actions under that person’s employer’s or organization’s account. 

In these instances, your employer or organization determines what personal information is provided to us, and what can be collected by us, under the institution’s or organization’s account. In other words, your employer or organization is the data controller for your personal information that is provided and collected in connection with its account with us. 

Because of that, your employer or organization is the party that is primarily responsible for the personal information about you that we collect in connection with your employer’s or organization’s account. And your employer or organization is the party that is primarily responsible for protecting the privacy of that personal information about you. 

In these circumstances, we are only a data processor. This means that we only carry out and process, via our Services, the activities of and instructions from your employer or organization (and/or the individuals using our Services under your employer’s or organization’s account). 

Simply put: when we process personal information about you that is provided by your employer or organization (or by you or another individual under your employer’s or organization’s account), we are not responsible for the disclosures made by your employer or organization (or those individuals under the employer or organization account). It is your employer or organization that has the responsibility to protect your privacy. 

Please note that the privacy and security policies of your employer or organization may differ from our policies. In those cases, our policies will not overrule or change the separate policies of your employer or organization, and our policies will not impact or change your employer’s or organization’s separate agreements with and obligations to you. Instead, the privacy and security policies of your employer or organization govern your personal information and your rights, and not our policies. As such, you are required to work with your employer or organization directly with respect to your personal information. 

Even though we are not primarily responsible for your personal information in these circumstances, we still want you to understand what personal information we might collect about you under these circumstances and how we collect that information. 

Employers and organizations (and/or individuals using our Services under employer and organization accounts) use our Services to send, process, store, publish, and otherwise distribute communications, information, messages, videos, and other content about or relevant to the employer or organization. Depending on what Services are used, and how they are used, some of that information may be restricted to limited recipients and/or viewers, and some of that information may be viewable by the public. Some of that information may include personal information about you. As explained above, the employers and organizations (and/or the individuals using our Services under employer and organization accounts) make those choices and are responsible for them.

Types of Information Collected

How We Collect It 

Personal information uploaded by an employer or organization (and/or individuals using Services under employer or organization accounts) 

We collect personal information that employers and organizations (and/or individuals using Services under employer or organization accounts) include in the communications, messages, videos, and other information stored, processed, published, and/or distributed via our Services (for example: information about one or more individual user(s) that are authorized to purchase products on behalf of employer or organization). Some of this information may contain personal information, like personal identifiers; and some of that personal information may be about you. 

Personal information related to activities under an employer or organization account 

We collect information about how our Services are used under employer and organization accounts. For example, we collect information about the individual pages on our Site and platform that are viewed, the features and functions on our Site and platform that are used, and other information about how the users under the account interact with our Services. We also collect information about what web browsers and IP addresses are used to access our Services, and the geographic location of that access. We may also collect information connected with our support and technical help for our Services. Some of this information may contain personal information, and some of that personal information may be about you. 

Account information 

We collect information that is provided for the creation, administration, and management of our employer and organization accounts. For example, we collect [contact details, employer and organization name, job title and position information, phone numbers, email addresses, log-in information, passwords, and other information necessary or helpful to provide our Services to the account holder. Some of this information is voluntary. However, please note that certain information is required to use and enjoy our Services. Some of this 

Please note that except as set out in these policies, [we do not collect or scrape additional information from the computers, contacts, email accounts, or other personal sources of account holders and individuals accessing or using our Services]. 

If you have questions or requests about your personal information or rights under your employer’s or organization’s account, you should address those questions and requests directly to your employer or organization. If you contact us regarding these questions and requests, we will forward your questions and requests to your employer or organization. 

Please note this section does not apply to personal information collected or stored from individual users or through an individual account (i.e., not under an account of an employer or organization). Our policies under those circumstances are addressed in the section 2.B immediately below. 

2.B Personal Information from Individual Users 

We collect several types of information from and about individual users, including information by which you might be personally identified. A few examples of how and when this may happen include: 

  • you access, download, log in, use, view content on, and/or otherwise interact with one of our websites, software, platform, or mobile applications; 
  • you purchase products via the Services; 
  • you submit personal information on one of our websites, software, platform, or mobile applications by uploading and publishing content, or by sending communications; 
  • you interact with us with respect to account maintenance or service (for example: billing or technical support, and product updates). 

Specifically, the following personal information may be collected: 

Type of Information Collected 

How We Collect It 

Personal information uploaded by you 

We collect personal information that you include in the communications, messages, videos, and other information stored, processed, published, and/or distributed via our Services (for example: information about one or more individual user(s) submitted while using the Services. 

Personal information related to activities under your account 

We collect information about how our Services are used under your account. For example, we collect information about the individual pages on our Site and platform that are viewed, the features and functions on our Site and platform that are used, and other information about how you interact with our Services. We also collect information about what web browsers and IP addresses are used to access our 

Please note that except as set out in these policies, [we do not collect or scrape additional information from the computers, contacts, email accounts, or other personal sources of account holders and individuals accessing or using our Services]. 

If you have questions or requests about your personal information or rights in connection with our product and services, please contact us by any of the methods set out above in the introduction to these policies or below in the section 9 titled “Contact Us”. 

Please note this section does not apply to personal information collected or stored from employers and organizations (and/or individuals using Services under employer or organization accounts) (i.e., not directly from individuals under individual accounts). Our policies under those circumstances are addressed in the section 2.A immediately above. 

2.C Generalized and Anonymous Information about All Users 

We may collect and use generalized, anonymous information about all visitors and users of Services. This information cannot be used to identify or isolate your personal information. If you have questions or requests about your personal information or rights in connection with our collection of generalized, anonymous information, please contact us by any of the methods set out above in the introduction to these policies or below in the section 9 titled “Contact Us”. 

3. HOW WE USE AND DISCLOSE YOUR INFORMATION 

We use and/or disclose personal information [solely for the purpose of providing and improving our Services] to and for our users. [We do not attempt to monetize personal information by selling or sharing it with third parties.] Specifically, we use and/or disclose personal information in the following ways: 

  • To operate our Services: We may use and/or disclose personal information when we store, process, publish, and/or distribute content that is included in information, communications, messages, or videos, or uploaded for storage, by our users via our Services; 
  • To personalize our Services: We may use and/or disclose personal information to personalize our Services for you, such as tailoring the content and information made available to you via the Services; 
  • To enable product purchases via our Services: We may use and/or disclose personal information to enable you to purchase products on our Services from us and various third parties. 
  • As you direct or consent: We may use and/or disclose personal information when you direct us, or consent to us, using or disclosing your information via our Services, or for the creation, administration, and management of user accounts; 
  • For legal purposes: We may use and/or disclose personal information (i) to comply with applicable laws, regulations, court orders, legal processes, or to respond to any government, agency, or regulatory request, (ii) to detect or otherwise manage fraud, security, or technical issues, (iii) to protect the safety, rights, or property of any person, the public, or OurPharma, or (iv) to enforce our rights arising from our contracts with employers and organizations, or individual users, including the Terms of Use (available at https://ourpharma.net/terms-of-service) and for billing and collection purposes; 
  • With third party vendors to provide, promote, or improve our Services: We may use and/or disclose personal information with third parties to provide, promote, and improve our Services (for example: to help us process and publish information, communications, messages, videos, and other information on our products, to help us process payments, to help us conduct campaigns and events, or to help us ensure compliance with appropriate security standards); 
  • To enable and transmit SMS/MMS/Mobile messages: We may use and/or disclose personal information to enable and transmit SMS/MMS and other mobile messages via our Services (for example: we may share personal information with messaging platform providers, phone companies, and other vendors who enable the delivery of mobile messages); 
  • To contact you about Services: We may use and/or disclose personal information to contact you about Services that may be of interest to you (for example: new features or new products; 
  • To contact you about events and other resources: We may use and/or disclose personal information to contact you about events and other resources that may be of interest to you (like webinars and the publication of new educational materials); 
  • For account servicing and maintenance: We may use and/or disclose personal information to help us with respect to account servicing and maintenance (for example: billing or technical support, and product updates); 
  • To measure and improve client engagement: We may use and/or disclose personal information to help us measure and improve our engagement with our users (for example: we use Google Analytics to help us understand how our users use our Services – you can read more about how Google uses our information here: https://www.google.com/intl/en/policies/privacy/ and you can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout); and 
  • For corporate business purposes: We may use and/or disclose personal information (a) to our current or future parents, affiliates, subsidiaries, and other companies under common control and ownership, or (b) to a buyer or other successor in connection with, or during negotiations for, a merger, acquisition, reorganization, or other sale or transfer of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. 

When we use and/or disclose personal information with third party vendors, [those vendors must abide by our privacy and security instructions and requirements. Third party vendors are not allowed to access or use information from us, except only as needed to do their particular work with us]. 

When we use and/or disclose personal information for legal purposes or in connection with our corporate business purposes, we will try to limit the information we provide as much as possible, and we will condition our sharing of that information on strict confidentiality restrictions as often as possible. 

We may also use and/or disclose anonymized or generalized aggregated information with third parties for various reasons, including to promote and improve our Services. In these circumstances, we will take appropriate measures to de-identify (and prevent any party from re-identifying) any information used or disclosed in this way. 

4. ADVERTISING AND MARKETING; TRACKING; OPT-OUT 

As explained above, we may use your information for limited advertising and marketing purposes, including to contact you about Services that we believe may be of interest to you, and to promote events and other resources that you may be interested in. 

Our marketing communications will include instructions for how to opt-out of all or a portion of these communications, or change your preferences. You may also contact us by email at [email protected] to manage your marketing communication preferences at any time. 

We may use cookies, beacons, and other similar tracking technologies. For example, we use cookies to help us measure and improve our engagement with our users by analyzing the usage trends and patterns for our websites, platforms, and mobile applications, and to promote Services that we believe may be of interest to you. In some cases, you may manage the use of cookies for our Services by adjusting your individual browser settings. You may learn more about managing cookies here: https://www.aboutcookies.org/. Please note that our Services do not currently process “do not track” features offered by some browsers and devices. 

5. CHILDREN 

We do not permit individual users or individual accounts for individuals under the age of 16. In addition, we do not knowingly collect any information about or from children under the age of 16. 

6. SECURITY OF INFORMATION; DATA RETENTION AND TRANSFERS 

The security of personal information is very important to us. Protecting your privacy and securing the information we store and transfer is very important to us, and we continuously work to do that well and to improve our privacy, data storage, and data transfer practices. We have taken and will continue to take steps that we believe are reasonable to safeguard against the unauthorized access and use of personal information. However, we cannot and do not guarantee the total security of your information in all circumstances. 

Please note that we are based in the United States, and your information will be transferred, processed, and stored in the United States and may be transferred, processed, and stored outside of the United States to any other country where we, our corporate affiliates, agents, and service providers operate (for example: for support and maintenance of our Services). Data protection laws differ among jurisdictions, and the United States and these other jurisdictions may not provide the same level of protection for personal information as your jurisdiction of residence. If you are from the European Economic Area (“EEA”) and we transfer your personal information to countries outside of the EEA, we will take appropriate steps to ensure your personal information is given the same level of protection as described in these policies. If you are located in the EEA or Switzerland, we comply with all legal requirements for the transfer of personal information to countries outside of the EEA or Switzerland. By using our Services, or providing us with any information, you are consenting to the transfer, processing, usage, sharing, and storage of your information, including personal information, in the United States and in the other jurisdictions where we do business. 

We may retain your information, including personal information, for as long as permitted under applicable law. For example, we may keep your personal data for quality assurance purposes for our Services or to defend future legal claims. We also will retain de-identified information after your account has been deleted. Information you have shared with others will remain visible after your account has been deactivated or deleted and after the information has been deleted from your own profile or account. We do not control information or content that others have copied out of our Services. Please note that copies of information that you have updated, modified, or deleted may continue to reside in our systems for a period of time, and we may maintain copies of this information as part of our business records. 

7. CONTACT US 

If you have questions about our policies or any related matter, please contact us at any of the following: 

  • • By email at [email protected]; 
  • • By telephone at (833)-290-2654; or 
  • • By mail at OurPharma Holdings, LLC, c/o Data Protection Officer, 2512 S. City Lake Road, Fayetteville, AR 72701. 

8. MISCELLANEOUS 

We use or may use third party providers for various aspects of our Services (for example: messaging functionality; processing of payments and fees). By using our Services, you will also be subject to the third party policies for those third party services. These third party policies may be materially different than our policies, especially with regard to information privacy and security. 

There may be links or references on our Services to other products or services that are offered by third parties. Please note that we are not responsible for the privacy and security practices and policies of any third party. If you choose to access or use any such third party product or service, you do so at your own risk. 

We may change these policies from time to time without notice to you. The most current version will always be at the following link: https://ourpharma.net/privacy-policy/. We may choose in our sole discretion to also notify you by email as a courtesy, but we are not required to. Any changes to these policies will be effective on a going forward basis. By continuing to use the Services after revisions are effective, you will be bound by the revised policies. If you do not agree with any updates to these policies, you may not continue to use the Services. Be sure to return to this page periodically to ensure you are familiar with the most current version of these policies. 

9. CALIFORNIA PRIVACY NOTICE 

At this time the OurPharma Services are not available to individual users who are residents of the State of California. Any attempt by an individual resident or California to use the Services will be automatically void. 

PLEASE NOTE IF YOU ARE USING THE SERVICES FROM CALIFORNIA UNDER AN ACCOUNT OF AN EMPLOYER OR ORGANIZATION, THE PRIVACY AND SECURITY POLICIES OF SECTION 2 ABOVE WILL CONTROL AND GOVERN YOUR PERSONAL INFORMATION AND YOUR RIGHTS. In these instances, please contact your employer or organization about your personal information and your rights. 

If you are an individual resident of the State of California and simply browse the Site, we do not collect or store personal information about you. 

For general reference, please also see section 2 above for more information about the personal information we collect from eligible users of the Services. Please also see section 3 above for more general information about how we may disclosure personal information of eligible users of the Services. 

10. EUROPEAN ECONOMIC AREA PRIVACY NOTICE 

If you are an individual resident of the European Economic Area (“EEA”), you have certain rights with respect to your personal information, including under the General Data Protection Regulation (“GDPR”). This includes, among other rights, the right to be informed and request access to the personal information about you that we have collected via our Services. You may also have the right to ask that your personal information be corrected, updated, or deleted. 

Please note that we will comply with valid requests from residents of the EEA subject to relevant legal exemptions. Please also note that we will need to verify your identity before processing any such requests, which may require us to request and obtain additional information from you. We will use that information only to review and address your requests. We reserve the right to decline or limit requests in certain circumstances – for example, when we are unable to verify your identity or locate information in our systems, or as otherwise permitted by applicable law. 

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under this section. Before accepting such a request from an agent, we will require the agent to provide us with proof that you have authorized it to act on your behalf, and we may also need you to verify your identity directly with us. 

If you use our Services under an account of an employer or organization, please contact your employer or organization about your personal information and your rights. Otherwise, if you have questions or concerns, or would like to exercise any of your rights under the GDPR or any similar right, as an individual user under an individual account, please contact us, care of our Data Protection Officer, at any of the following: 

  • By email at [email protected]; 
  • By telephone at (833)-290-2654; or 
  • By mail at OurPharma Holdings, LLC, c/o Data Protection Officer, 2512 S. City Lake Road, Fayetteville, AR 72701. 

You may also contact the data protection authority of your jurisdiction. 

Last updated on July, 2021