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This privacy notice (“Privacy Notice”) discloses the privacy practices by Comprehensive Pharmacy Services, LLC (“CPS”, “family of PPS Holdings, Inc. companies”, “we”, or “us”) for its website, (www.cpspharm.com) (the “Website”).  CPS is the sole owner of any data collected through the Website.

This Privacy Notice only applies to information collected via this website. This Privacy Notice outlines the following:What is personally identifiable information (“PII”);What categories of PII are collected through the Website;

1.What categories of sources from which we collect your PII;

2.Why we collect your PII;

3.How do we share your PII outside of CPS;

4.The categories of sources with which we share your PII;

5.What choices you have regarding how we collect, use, and share your PII;

6.How we protect your PII; and

How you can submit your requests to access or delete your PII, or opt out of the sale of your PII (applicable to California residents only).

What is Personally Identifiable Information (“PII”)?

CPS defines Personally Identifiable Information as information we collect that can either identify you or that can be reasonably linked to you.  Such information that CPS collects about you on the Website includes your first name, last name, email address, postal address, phone number, or information regarding your interaction with the Website.

What Categories of PII Are Collected Through the Website?

CPS may collect the following categories of PII through the Website, although not all categories may be collected about every person:

  • Identifiers provided to CPS by you (such as first name, last name, email address, home mailing address, and/or phone number);
  • Professional or employment-related information (such as job title, organization or Integrated Delivery Network name); and/or
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding the person’s interaction with an internet website, application, or advertisement.

What are the Categories of Sources From Which We Collect PII?

You may actively share information with CPS via the Website, such as:

  • Personal identifiers like your first name, last name, email address, home mailing address, and phone number; and
  • Any other information you may share in the “Comments” section of the Website.

Sensitive information, such as your social security number, credit/debit card number, or medical information, should not be entered into the “Comments” section of the Website.

You will passively share information with CPS via the Website such as:

  • Internet or other electronic network activity information including browsing history and information regarding your interaction with the Website.

Why Do We Collect Your PII?

CPS uses the PII you provide to respond to you regarding the reason that you contacted us. We may share your information within CPS in order to have the most appropriate resource information for you regarding the reason you contacted us.

CPS also may use your PII to support our business functions such as marketing and trend monitoring.  CPS may also use your PII as part of our efforts to keep the Website secure and improve the format in which content is presented to you.

How Do We Share Your PII Outside of CPS?

We will not share your information with any third party outside of CPS, other than for a business purpose, as described below.  We also do not share your personal information with third parties for such third parties’ direct marketing purposes. We do not sell or rent your PII for monetary consideration.  We may share your PII in limited circumstances, such as to conduct our business, or in the event all or a part of our business is merged, sold or reorganized, when legally required, as described below, or with our consent.  Additionally, unless you ask us not to, CPS may contact you via the email address you provided in the future to tell you about new products or services or to communicate changes to this privacy notice. 

We may share your PII with service providers that help with our business activities, including customer service support vendors and companies that help us improve our products and services.  We require our service providers to keep your PII secure, and we do not allow our service providers to use or share your PII for any purpose other than providing services on our behalf.

We may share your PII in special circumstances, which include situations when such sharing is required by law, or we believe sharing will help to protect the safety, property, or rights of CPS, our affiliates, our clients, employees, or other persons.  Special circumstances in which we may be required, or in which we may desire to share your PII for safety reasons, include: protecting the health or safety of our clients or employees, addressing crimes committed on our property, identifying and addressing fraud or financial risk, responding to search warrants or other valid legal inquiries, and responding to investigatory or regulatory bodies in the case of a breach of an agreement or violation of law.

Additionally, in the event that all or a part of our business is merged, sold, or reorganized, your PII could be shared with the successor entity.  We will work with the successor entity and use reasonable measures to treat your PII in accordance with this Privacy Notice.

Except for the situations described below, we will ask for your affirmative consent before sharing your PII outside our family of companies.

How do we protect your PII?

We value the trust you have placed in us to provide your PII.  As such, we are committed to protecting your information and privacy. When you submit PII via the Website, your information is protected both online and offline.  Wherever CPS collects PII, that information is encrypted and transmitted to us in a secure manner. You can verify this by looking for a lock icon in the address bar and looking for “https” at the beginning of the address of the Website.

While we use encryption to protect PII transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, marketing) are granted access to PII. The servers in which we store PII are kept in a physically secure environment.

Your California Privacy Rights

How Do You Submit Requests to Access or Delete Your PII, or Opt Out of the Sale of Your PII (California Residents Only)?

If you are a California resident, you may submit to us certain requests regarding your personal information, and we will fulfill your requests to the extent we are required by law.  The process listed below should also be followed if you are an authorized agent of a California resident whom wishes to submit to us certain requests regarding their personal information.

If you want to submit a request to access or delete your personal information, or to opt out of the sale of your personal information, you can contact our toll-free number, 1-833-450-4229, or email privacy@cpspharm.com with your first name, last name, home mailing address, preferred contact information (for example, your email address or telephone number), and your request.  The information you provide when submitting your request will only be used to verify your identity and identify you in our data or the data of our service providers.  We will send you a written confirmation that we have received your request via the communication method you choose (email or postal mail) along with any follow-up questions or instructions for us to complete your request.  You must submit a separate request for each individual request to access or delete your personal information or to opt out of the sale of your personal information to ensure the request is handled properly.

Specifically, you may:

  • Request that we disclose to you the PII we have collected or shared within the 12 months prior to your request, including the list of categories of PII we have sold and/or shared with another company for a business purpose;
  • Request that we delete your PII; or
  • Request that we stop selling your PII.

If you request a disclosure of your PII, we will provide to you, to the extent required by law:

  • The categories of PII we have collected from or about you,
  • The categories of sources from which we collected your PII;
  • The business or commercial purpose for which we collected or sold your PII;
  • The categories of third parties with whom we shared your PII; and
  • The specific pieces of PII we have collected about you.

If you request that we delete PII that was collected from or about you, we will, to the extent required by law:

  • Delete your PII from our records; and
  • Direct any service providers to delete your PII from their records.

If you request that we stop selling your PII, we will, to the extent required by law:

  • Not sell your PII to third parties unless you subsequently provide express authorization for the sale of your PII;
  • Not require you to create an account in order to direct us not to sell your PII;
  • Use any PII collected from you in connection with your request for us to stop selling your PII solely for the purposes of complying with your opt out request; and
  • Respect your decision to opt out of the sale of your PII for at least 12 months before requesting that you authorize the sale of your PII again.

We will not discriminate against you because you exercised any of the rights listed in this Privacy Notice including, but not limited to, by:

  • Denying goods or services to you;
  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Providing a different level of quality of goods or services to you; or
  • Suggesting you will receive a different price or rate for goods or services or a different level or quality of goods or services

CPS may still use any aggregated and de-identified personal information that does not identify any individual and may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Please note that CPS is not permitted to provide medical or financial information through this request process.  All requests for medical or financial information must be submitted to the facility where you received healthcare services (for example, a hospital or retail pharmacy), even where CPS is a service provider at that facility.

If you do not wish to receive future emails from us, please email privacy@cpspharm.com and include the following information:

  • Type “Opt Out of CPS Marketing” in the email subject line; and
  • In the text/content of the email, include the email address(es) that need to be opted out and the first and last name of the individual making the request.

If you feel that we are not abiding by this privacy policy, you should contact us immediately via telephone at 833-450-4229 or at privacy@cpspharm.com.

This privacy notice was last updated on 06/30/2020.