Effective Date: 5.2.2023

Pharmacy Quality Solutions, Inc., PQS (“PQS”, “we”, or “us”) respects your privacy. This Privacy Policy (“Policy”) describes how we collect, use, protect and disclose your Personal Information in connection with your use of our website, https://www.pharmacyquality.com/, along with the website’s features, functionalities, and applications (“Website”).

If you have any questions about how we collect, use, protect or disclose your Personal Information in connection with our Website, please contact us by email at privacy@pharmacyquality.com.

Personal Information We Collect

We collect Personal Information to facilitate purchases, provide and improve our Website, and conduct our business operations. Depending on how you use our Website, we may collect the following categories of Personal Information about you:

• Identifiers: Contact and other identifying information, such as your real name, birthday, email address, telephone number, online identifier, and IP address.
• Commercial Information: Information about the products or services you have purchased, obtained, or considered; and other information about your purchasing or consuming histories or tendencies.
• Device information: Information such as the IP address, general geographic location, operating system, browser type, language preferences, mobile phone number, device identifier and other similar information associated with the device you use to access, use, or interact with the Website.
• Geolocation Data: Location information, such as the city, state and ZIP code associated with your IP address.

Other information you provide us.

How We Collect Personal Information

A large portion of the Personal Information we collect is collected directly from you. In some cases, we may collect Personal Information from third parties in the ways described in this Policy.

Directly from You

When you access, use or otherwise interact with our Website, or otherwise engage with us in connection with our Website, such as when you create an account with us, we may ask you to provide certain Personal Information.

Automatic Data Collection

We may collect certain information automatically through our Website, such as your IP address, mobile carrier, and other device identifiers that are automatically assigned to your computer or device when you access the Internet.

Information from Third Parties

We, or third parties acting on our behalf, may collect Personal Information about you from third parties, including, without limitation, online and offline sources, entities affiliated with us, our service providers, social media platforms, advertising networks and other public or commercial sources (collectively, “Third Party Sources”). The collection of Personal Information from these Third Party Sources can occur in a variety of ways, including, without limitation:

• We, or third parties acting on our behalf, may receive Personal Information about you from third parties that provide services to us through or in connection with the performance of our Services or the operation of our Website (“Service Providers”).
• We may receive certain information from third party apps and websites when you choose to integrate your account on those apps or websites with your account on our Website.
• We may receive information from third parties whose content is linked to on our Website. Any links to other websites, applications or other third-party content on our Website, are not an endorsement, authorization, or representation of our affiliation with that third party and we are not responsible for the content, privacy and security policies and practices of any third party. We encourage you to read the privacy policies or statements applicable to any third-party websites, applications, or content you access.
• We, or third parties acting on our behalf, may also receive Personal Information about you from other third parties, such as other users of our Website, including without limitation, those that refer you to our Website.

Please note, we may combine the Personal Information and other content and information we receive about you from multiple sources, including, without limitation, Personal Information we collect directly from you and one or more Third Party Sources.

How We Use Personal Information

The primary purposes for which we use Personal Information are:

• Customer Service and Customer Communications. We may use Personal Information (1) to fulfil orders and (2) send you emails, calls, and text messages to provide you with alerts and updates about your engagement with the Website.
• Provide our Services. We may use Personal Information to provide you customized results when you use our Services.
• Business Purposes. We may use Personal Information for business purposes including but not limited to: (1) carrying out our obligations and enforcing our rights arising from any contracts we have entered into, including, without limitation, any contracts between you and us; (2) operating and improving our products and Website; (3) conducting statistical or demographic analysis; (4) customizing your experience with our Website; (5) preventing fraud; (6) assessing the success of our marketing and advertising campaigns; (7) registering accounts; and (8) other business purposes permitted under applicable law.
• Marketing Purposes. We may use your Personal Information to advertise and market to you including notifying you of special promotions, sweepstakes and contests, opportunities, offers and events via push notifications, e-mail, and other means. We also use Personal Information to serve you targeted ads.
• Law Enforcement/Legal Purposes. We may use Personal Information to cooperate with law enforcement or other legal purposes including: (1) complying with legal and regulatory requirements; (2) cooperating with law enforcement or other governmental agencies for purposes of investigations, public safety or matters of public importance when we are legally required to do so or believe that disclosure of Personal Information is necessary or appropriate to protect the public interest; and (3) protecting and defending against legal actions or claims.

Please note, we may use and disclose aggregated, anonymized, or de-identified information collected in connection with our Website and other information that does not identify any individual (“Anonymized Data”) for any lawful purposes, which may include, without limitation, purposes not described in this Policy. Except as otherwise required under applicable laws, our use and disclosure of such Anonymized Data is not subject to this Policy.

Sharing Personal Information with Third Parties

To operate our Website and provide our Services, we may share your Personal Information with certain third parties including:

• Service Providers. We may share Personal Information with Service Providers. The types of Service Providers to whom we entrust Personal Information include Service Providers for: (i) provision of IT, analytics, and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities such as deliveries and member support; and (v) in connection with the provision of the Website.
• Business Providers. We may share Personal Information with our business partners and affiliates for our business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners with whom we jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with PQS.
• Marketing Partners. We may share Personal Information to facilitate the delivery of targeted ads, promotions and offers to you, on and off the Website.
• Parties to Business Transactions. In the event of an anticipated or actual merger or acquisition, bankruptcy or other sale of all or a portion of our assets, we may transfer or allow third parties to use information owned or controlled by us, including Personal Information. We reserve the right, in connection with these types of transactions, to transfer, share, assign, or sell your Personal Information and other information we have collected to third parties or to authorize such third parties to use any such information including for due diligence as part of any of the transactions described in this paragraph. Any Personal Information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
• Government and Law Enforcement. We may share your Personal Information with individuals or private parties where necessary to enforce and comply with the law, to protect our property or legal rights, for the safety of the public or any person, to prevent harm, to protect the security and integrity of the Website.
• Professional Advisors. We may share Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors, and business advisors, in their capacity as advisors to us.
• We may share Personal Information with third parties and/or Service Providers at your request or with your explicit consent.

TOOLS WE USE AND YOUR CHOICES

Cookies and other Tracking Technologies

We use cookies and other tracking technologies including pixel tags and web beacons to gather more information about how our Website is used. A “cookie” is a small text file that our Website saves onto your computer or device when you use the Website that allows the Website to remember your actions and preferences and recognize you or your browser. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.

We use these tools to learn whether the Website is operating optimally, learn whether you are a repeat visitor to our Website, personalize advertising, obtain valuable data and statistics about the usage and effectiveness of our Website, and help us provide an enjoyable, personalized and innovative online experience for you. We may combine information gathered from cookies with other Personal Information.

Generally, the type of information we collect through cookies and other tracking technologies is specific to your computer or other device and includes the IP address, date and time the device accessed our Website, what parts of our Website were visited, your internet services provider, the device ID number, approximate geographic location, browser type, the websites you visit before and after coming to our Website, and whether the web pages requested were delivered successfully.

The Options/Settings section of most internet browsers will tell you how to manage cookies and other technologies that may be uploaded to your device, including how to disable such technologies. You can disable our cookies, or all cookies, through your browser settings, but please note, disabling cookies may impact some of the features of our Website and prevent them from operating as intended. You can learn more about cookies, including how to see what cookies have been uploaded to your device and how to manage and delete them, by visiting https://www.allaboutcookies.org/.

Analytics Tools

We use third-party analytics tools, including those listed below.

• Google Analytics. Google Analytics is a web analytics tool that assists us in understanding how our Website is used. Google Analytics will place cookies on your device that will generate information we select about your use of the Website, including your device’s IP address. That information will be transmitted directly to and stored by Google. The information will be used for the purposes of evaluating use of the Website, compiling reports on activity on the Platform for our use and providing other services relating to activity on, and usage of, the Website. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google’s practices with respect to the Personal Information collected through Google Analytics are covered by Google’s privacy policy, available at https://policies.google.com/privacy. You may opt-out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.
• Google Tag Manager. We may use Google Tag Manager (“GTM“), a tag management system that allows JavaScript and HTML tags to be quickly deployed and updated on portions of our Website for tracking and analytics. We use GTM on our Website to include Google Analytics. If you have opted out of Google Analytics, GTM takes this opt out into account. For more information about Google’s privacy practices applicable to GTM, please refer to https://policies.google.com/privacy/ and the terms of use at https://www.google.com/analytics/tag-manager/use-policy.

Interest Based Advertising

• LinkedIn Ads is a paid marketing tool that offers access to LinkedIn social networks through various sponsored posts and other methods. LinkedIn Ads is a powerful marketing tool for B2B companies to build leads, online recognition, share content, and more. LinkedIn provides sponsored content, such as, Message Ads, Dynamic Ads, Text Ads, or a mix of all four. Sponsored Content appears directly in the LinkedIn feed of professions you want to reach and comes in three different formats: single image ads, document ads, video ads, and carousel ads.
• Twitter advertising is a function of Twitter; it allows advertisers to target content and promotions to Twitter users. Twitter advertising is a form of display advertising and comes in three forms: Promoted Tweets: where the advertiser has paid for increased reach on a post, Promoted accounts: where the advertiser has paid for increased account exposure, Promoted trends: where advertisers pay to promote a specific topic.

MARKETING, PROMOTIONAL EMAIL, AND TEXT COMMUNICATIONS

Email and Marketing

• You can opt-out of receiving marketing and other promotional email communications we send you by following the unsubscribe instructions contained in most email messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional marketing and other promotional emails from us. Please note, opting out of these communications will only apply to marketing and other promotional emails and will not apply to any email or other communications we send to you for non-marketing purposes, including, but not limited to, emails and other communications about your interactions with our Website.

Website Notifications

• We may send you push notifications via the website, if you opt-in. If you wish to opt-out from receiving these types of communications, you may request to be removed from this function.

Social Media

• We are active on social media, including Facebook, Instagram, LinkedIn, Twitter, Podcasts, and YouTube (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Website and our Social Media pages any comments or content that you post on our Social Media pages. Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate these platforms.

Text Communications

• As per the “Terms of Service” of the Pharmacy Quality Solutions website, www.pharmacyquality.com/termsofservice, by providing your mobile number and opting-in, you consent to receive mobile text alerts regarding EQUIPP communications. You may receive recurring EQUIPP text messages and survey abandonment reminders messages. Receiving a text message is not a requirement for participation in this program. You understand that we will send mobile text messages using automated technology, adhering to relevant regulations. We are committed to the security and privacy of your personal information, including your mobile number, and our data practices comply with applicable data protection laws. Details on how we handle, store, and protect your data can be found in our Privacy Policy. By signing up, you are confirming you are over the age of 13, in compliance with the Children’s Online Privacy Protection Act (COPPA) and similar applicable laws. If you have any questions or concerns about your privacy or data security, please reach out to us at privacy@pharmacyquality.com. Additionally, if you wish to exercise your subject rights under data protection laws, including the right to access, rectify, or delete your personal data, please contact us at privacy@pharmacyquality.com, and we will assist you in accordance with applicable regulations.

SECURITY OF INFORMATION

We are committed to protecting the security of your Personal Information. We use commercially reasonable safeguards to maintain the security and privacy of Personal Information we collect and use in connection with our Website. Nevertheless, when disclosing Personal Information, you should remain mindful that there is an inherent risk in the transmission of information via the internet and mobile platforms. Although we take precautions to protect against the risk of unauthorized access to your Personal Information, we cannot guarantee the security of any information, including your Personal Information, that you disclose online and you do so at your own risk.

Children’s Privacy

Our Website is not directed to children under the age of 13. In addition, you are not permitted to use our Website if you do not meet the minimum age requirement applicable to our Website in your jurisdiction. We do not knowingly collect Personal Information from children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us and we will take steps to delete such information from our files as soon as possible.

California Privacy Rights

If you are a California resident, under California’s Shine the Light Law (California Civil Code Section 1798.83) you have the right to request the following information regarding our disclosure of your Personal Information to third parties for direct marketing purposes: (1) the categories of Personal Information we disclosed to third parties for their direct marketing purposes during the preceding calendar year; (2) the names and addresses of the third parties that received the information; and (3) if the nature of the third party’s business cannot be determined from their name, examples of the products or services they marketed. This information may be provided in a standardized form that is not specific to you.

You are permitted to obtain this information from us once a year, free of charge. To make such a request, please submit your request in writing to:

PQS, LLC.

Attn: Legal Department

4711 Hope Valley Rd, Ste 4F-811

Durham, NC 27707

FOR USERS IN THE EUROPEAN ECONOMIC AREA (EEA) AND OTHER SPECIFIC USERS.

To the extent the General Data Protection Regulation (GDPR) or other law granting particular rights to data subjects applies to you, you have the following rights with regard to our processing of your personal data to the extent made available by the applicable law:

PQS as the Data Controller

When you provide us with your Personal Information through our Sites or App or otherwise in connection with our Service, we serve as a data controller.  When we act as a data controller we determine how personal data will be utilized, in accordance with this Privacy Policy.

Our Legal Basis for Processing Your Personal Data

The following sets out our four (4) lawful bases under the GDPR to which PQS may process your personal data:

• Our Contract With You: Our processing is necessary to perform our obligations under a contract with you or to perform steps requested by you prior to entering into a contract with you (e.g., to verify the information you have provided to us).
• Our Legitimate Interests: Where our processing is necessary for the purposes of the legitimate interests pursued by NFI, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data. These legitimate interests include the protection and the security of our Service; to protect the health and safety of you or others; to establish, protect and defend our legal rights and interests; to prevent fraud and verify identity and authorization of clients; to understand and analyze usage trends; and to improve our products and Service.
• Legal Compliance: Where our processing is required to comply with applicable law (for example, to maintain your payment transaction history for tax reporting purposes: e.g., in response to subpoenas, court orders and other lawful requests by regulators, courts and law enforcement agencies, or related to national security requests).
• Your Consent: Where you have given consent to process your personal data for one or more specified purposes, such as to provide our Service and other services requested by you.

Data Subject Rights:

Access and Control of Your Information

We enable you to have control over your personal data. To protect your privacy, before we give you access or let you access or update your personal data, we may ask you to verify your identity or provide additional information. We will try to update and allow you to access your personal information for free, but if it would require a disproportionate effort on our part, we may charge a fee. We will disclose the fee before we comply with your request. We may reject a request for a number of reasons, including, for example, that the request risks the privacy of other users, requires technical efforts that are disproportionate to the request, is repetitive, or is unlawful.

Right to Rectification

You have the right to correct your personal data if incorrect, which also includes the right to have incomplete personal data completed.

Data Portability

When we process your personal data by automated means that you have provided to us based on consent or through a contract, you have the right to get a copy of that data in a structured, commonly used and machine-readable format and have that transferred to you or to third party.

Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data:

• During the pending period of time where we verify the accuracy of any personal data that you claim is inaccurate;
• Where the processing of your personal data is unlawful but you oppose erasure and instead request that we restrict the use of your personal data;
• If we no longer need your personal data but it is required for you to make or defend legal claims; or
• During the pending period of time where we verify our legitimate interest to process your data when you object to such processing.

Right to Object

You have the right to object to the processing of personal data under certain conditions. For example, you may object to any processing of your personal data where we have relied on legitimate interests as our legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interest. If you raise an objection, we will always respond to your request, but may not be required to honor it in all circumstances.

Erasure of Personal Data

You have the right to delete the personal data collected through our Services. There may be instances where we may not be able to delete your data or where we retain a copy of your data, for example, where we may need it to comply with a legal obligation or to protect the rights of others.

How to Exercise Your Rights

Address of Agent: Compliance Department
Email: privacy@pharmacyquality.com

Right to Complain to Supervisory Authority in the European Union

If you believe that PQS is processing your personal data in an incorrect or unlawful manner, please contact us at privacy@pharmacyquality.com.  For those located in the European Union, you also have a right to file a complaint with a Supervisory Authority in the EU.

INTERNATIONAL TRANSFER OF INFORMATION COLLECTED

Personal data PQS collects from you will be stored and processed in the United States.  If you provide us with personal data, it will be transferred to, processed, and accessed in the United States.

YOU CONSENT TO ANY AND ALL INFORMATION YOU PROVIDE AND SUBMIT VIA THE SITE BEING SENT TO THE UNITED STATES OF AMERICA.  The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. PQS relies on derogations for specific situations as set forth in Article 49 of the GDPR.  YOU ARE ALSO INFORMED THAT THE UNITED STATES PRESENTLY DOES NOT HAVE AN ADEQUATE LEVEL OF PERSONAL DATA PROTECTION AS DETERMINED BY THE EUROPEAN COMMISSION’S ADEQUACY DECISION ON OCTOBER 6, 2015 (Case C-362/14) AND ARTICULATED IN THE EUROPEAN UNION’S GENERAL DATA PROTECTION REGULATION AND HAS NOT RECEIVED A SIMILAR DESIGNATION OF ADEQUACY BY ANY OTHER FOREIGN DATA PROTECTION AUTHORITY.  YOU AGREE TO THE TRANSFER OF YOUR DATA AND PERSONAL DATA TO THE UNITED STATES, HOWEVER, TO BE USED IN ACCORDANCE WITH THIS PRIVACY POLICY.

Changes to this Privacy Policy

We may update this Privacy Policy at any time. When we do, we will revise the updated date at the top of this page. We encourage you to return to this page for any changes and to stay informed about our privacy practices. Please cease using our Website if you do not agree with any of our changes.

Contact Us

We welcome your questions, comments, and concerns about privacy. Please email us at privacy@pharmacyquality.com with any questions or feedback you have pertaining to our privacy practices.