LAST UPDATED: January 16, 2019

WHAT THIS PRIVACY POLICY COVERS
The Privacy Policy explains how FarmaceuticalRx, LLC (“we,” “us,” “our”) handles your personal information including:

  • The information you provide on our website, www.farmaceuticalrx.com (the “Site”), the FRX Mobile App (the “App”) and other communications with us;
  • The information we and others collect when you visit the Site, such as your IP address, device ID, and data from cookie and similar technologies that may be identified with you.
  • When and with whom we may share your information; and
  • Your choices and how to contact us about your information.

The term “personal information” as used in this Privacy Policy refers to (1) information that identifies you directly such as your name, street address, or e-mail address, and (2) other information, such as your IP address, device ID, and data from cookie and similar technologies, that may be identified with you.

YOUR CONSENT TO OUR PRIVACY POLICY, WEBSITE TERMS OF USE AND MOBILE APP TERMS OF USE
Please read our Privacy Policy, Site Terms of Use (if you are accessing the Site) and/or Mobile App Terms of Use (if you are accessing the App) carefully. When you use our Site and/or the App, you signify to us that you have read, understand, and agree to this Privacy Policy and Site Terms of Use (if applicable) and the App Terms of Use (if applicable), and that you also consent to the processing of your personal information as described in this Privacy Policy. You should not submit information to us either through our Site, the App or other communications if you do not agree to the terms of our Privacy Policy and the Site Terms of Use and/or App Terms of Use.

WHAT PERSONAL INFORMATION DO WE COLLECT?
Information You Provide Voluntarily. If you request information or establish an account either through our Site, the App or other communications, we will request your name and the following information, as applicable:

Contact information—first and last name, e-mail address, street address, and/or telephone number;
Identification—date of birth (to verify your age for legal purposes); user name and password if you sign up with us; and any other personal information or unique preference information you choose to provide to us.

User posted content—comments, questions and answers, chats, etc., using interactive Site features as available.

Optional Information—In order to enable us to improve the Site and the App and to better learn how patients seeking medical marijuana treatment can best be served, you will be asked, but not required, to provide us with: a) your patient biological data (e.g., hair color, eye color, blood type, ethnicity, date of birth, etc.); b) your family’s medical history; c) your health habits (e.g., smoker/non-smoker, how often do you consume alcohol, etc.); d) a list of the current medications, nutraceuticals and supplements you are taking; and e) current and past medical conditions (e.g., surgeries, diabetes, high blood pressure, heart disease, cancer, etc.)

Information Collected Automatically Using Technology. When you use our Site or App, data is collected by Company and our marketing partners about you and your online activities. We log IP addresses and other device, usage, and location data. Cookies, web beacons, and tags are placed on your computer when you access our Site.

We use Google and Facebook analytics tools to recognize you, record how visitors use our Site and App and browse online, record and measure customer support interactions, and report statistics about Site and App usage and the demographics of our user base. We also may partner with third parties in order to provide you with advertising based upon your browsing activities and interests or to manage our advertising on other websites. The types of data collected using these technologies include:

Identification—date and time of your visits to our Site, history of visits, user name and password if you establish an account, and date and time of content you post, and wallet address if you use cryptocurrency;

Device—your IP address, internet domain name, browser type, operating system, mobile network, device telephone number;

Usage—previous website, history of Site pages viewed, usage of Site features, time spent viewing each page, number and duration of visits, participation in tournaments hosted on the Site and other interactive Site and other internet activities that reflect your interests;

Social Media Information–your likes, interests, music, demographics, friends, relationship status and other information available from your Google and Facebook accounts (if your privacy settings on Facebook and Google have been enabled as such); and

Location—general geographic location determined by your IP address and more specific location from mobile device use (unless blocked).

For information about how we use information collected using these technologies, see “HOW DO WE USE AND SHARE INFORMATION?”

Restricting the Use of Information Collected Using Technology. You can control how these technologies are used to track and log your online activities in several ways:

Managing the preference settings on your browser and device;
Communicating directly with Google as explained at: https://policies.google.com/privacy;
Purchasing a utility from an independent software provider that you install on your computer browsers to limit tracking of your browsing activity; and
Visiting www.aboutads.info/choices to learn more about personalized advertising and how to opt-out of personalized advertising on your web browser and mobile apps by companies participating in the Digital AdvertisingVisiting www.aboutads.info/choices to learn more about personalized advertising and how to opt-out of personalized advertising on your web browser and mobile apps by companies participating in the Digital Advertising Alliance.

If you restrict the use of cookies and other technologies, you may not be able to use all the features of our Site. If you chose to restrict personalized advertising, you will still receive ads, but they will not be personalized.

Our Site does not respond to “do not track” requests.

HOW DO WE USE PERSONAL INFORMATION?

We use the personal information obtained on our Site and App for a number of purposes including, but not limited to, the following:

  • Verify your eligibility to pre-order products using the Site;
  • Customize a response to your inquiries via the App;
  • Establish and administer your Company user account if you sign up with us;
  • Administer services, which means that we may contact you for reasons related to the services you have signed up for (e.g., to provide you with password reminders or to notify you regarding a particular service);
  • Contact you about a submission you have made to the Site or App, including any content you provide;
  • Send you, or our third party partners may send you, e-mails, e-newsletters, personalized offers or other communications about our products and services;
  • Identify your usage of our Site and App, the number of visits (including via IP address logging) from different locations and/or devices, and your online browsing;
  • Customize the advertising and content you see on the Site and/or App;
  • Block and control disruptive use;
  • Analyze and improve the services we offer;
  • Use or share de-identified personal information for statistical or analytical purposes (note that de-identified data is not subject to this Privacy Policy).

Our use of your personal information for the purposes listed above is subject to the following limitations:

  • The terms of this Privacy Policy;
  • The terms of the Site Terms of Use and App Terms of Use;
  • Any terms applicable to the services or actions you request;
  • Your instructions to us to limit the use of your information; and
  • The requirements of applicable law, including data protection laws governing the collection and use of personal information.

WHEN DO WE SHARE PERSONAL INFORMATION?
Affiliated Companies and Partners. Our current affiliates and partners are: FRX, FRXHealth, FRX IP Holdings, FRXLabs, FRXGrow, FRXFarm, M2&ME, and Heard Marketing, LLC. These companies work with us to deliver our Services and partners may be added to this list as identified. They are obligated to protect the personal information of our guests and others who use our Services and they are not permitted to use your personal information for any purpose other than to carry out their responsibilities on our behalf.

Service providers. We share information with third-party service providers who provide support for our business operations. These may include payment processing, data and credit verification, hosted services such as those used to track and ticket questions and service requests; data center and other data storage, technology support services, email marketing services, e-commerce contact management services, and maintenance and security. For some of these services, the provider needs your personal information in order to perform the service, such as processing a payment, confirming creditworthiness, or verifying identity. For other services, the provider may have technical access to your information but does not need or use the information in order to perform the contract service, such as hosting an application or database or providing network infrastructure support. We take commercially reasonable measures to select service providers who demonstrate their commitment to protecting the personal information we entrust to them and who maintain privacy guidelines that are consistent with our Privacy Policy.

Data Analytics. While you use the Site and/or the App, information is passively collected about you and your online activities by data analytics companies including Google and other companies we authorize. These third parties provide reports to us about our Site and App usage and user behavior and demographics. They may also use the information collected on our Site and/or App for their own business purposes as long as the data is maintained in a form that does not reveal any information that identifies you individually. To learn more about how Google collects and processes data from websites for advertising and data analytics purposes, please visit https://policies.google.com/technologies/partner-sites. To learn more about the controls Google offers to manage the collection and use of your personal information, please visit https://policies.google.com/privacy.

Your use of the iOS version of the App also is subject to Apple, Inc.’s (“Apple”) Privacy Policy for apps available through the iTunes store. You can see Apple’s Privacy Policy at https://www.apple.com/legal/privacy/en-ww/.

Marketing and Advertising. We may contact you directly about our services and products that may be of interest to you, and may also exchange with or sell your contact information to third parties, which they may use to contact you directly for their marketing purposes. We may partner with third parties to display advertising on our Site and/or App and to manage our advertising on other websites and social media platforms. These third parties will use technologies such as cookies to gather information about your activities on our Site and other websites in order to provide you with advertising based upon your browsing activities and interests, and for other commercial purposes. You may opt-out of receiving direct marketing or interest-based ads, but will continue to receive general ads. See “HOW TO OPT-OUT OF PROMOTIONAL E-MAILS AND PERSONALIZED ADVERTISING” below.

Legal Process and Site Protection. We may disclose your personal information to third parties without notice to you in order to comply with applicable law, law enforcement agencies, enforce our Site and App policies, protect our rights, or protect the rights of other users of the Site and App. We may disclose information to companies assisting in fraud protection or investigation.

Business Transactions. In order to prepare for or undertake a business transaction, such as a financing, reorganization, or business sale or transfer, where we have a legitimate interest in disclosing personal information, subject to appropriate confidentiality protections, we may share personal information with transaction parties and their advisors; and retain a copy of the information following the transaction.

HOW TO OPT-OUT OF PROMOTIONAL E-MAILS
At any time, we will honor your request to unsubscribe from further e-mail marketing communications by clicking on the link at the end of each e-mail message. Or, you may instruct us to stop sending e-mails as explained in “HOW TO CONTACT US” below.

YOUR CALIFORNIA PRIVACY RIGHTS
Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us, once per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2019 will receive information regarding 2018 sharing activities). To obtain this information from us, please send an e-mail message to [email protected] with ”Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing (if any) will be included in our response.

NO CHILDREN UNDER AGE 18
The Company services are not intended for use by anyone under the age of 18, nor do we knowingly collect personal information from anyone under the age of 18. Certain features of the Site are only intended for use by Ohio residents over the age of 18 who have a validly issued medical marijuana card. If you are under 18, you may not attempt to register for an account or send any information about yourself to us, including your name, e-mail address or other contact or personal information. If we discover that we have collected personal information from someone under the age of 18 without verification of parental consent, we will delete that information promptly. If you are a parent or legal guardian of a child under 18 and believe that we might have any information from or about the child, please contact us as provided under “HOW TO CONTACT US” below.

HOW LONG DO WE KEEP PERSONAL INFORMATION?
We retain personal information for as long as we reasonably require it for business or legal purposes. When we no longer have a legitimate business interest in keeping your personal information, we securely delete or destroy it. In determining data retention periods, Company takes into consideration applicable laws, contractual obligations, and what we reasonably believe are the expectations and requirements of our customers and Site visitors. For example, if you submit an order or information request, we will retain your contact and preference information and consider our relationship to remain active for marketing purposes after fulfilling any request you submit and until we take note that you no longer show interest in our products or services.

HOW DO WE PROTECT PERSONAL INFORMATION?
We use commercially reasonable organizational, technical, and physical safeguards to protect the security, confidentiality, and integrity of your personal information and to meet the standards of this Privacy Policy and require third parties who can access your information to do the same. We limit access to personal information to our staff and service providers who we believe reasonably need to come into contact with that information to provide services to you or do their jobs. When you enter sensitive information (such as your password),we encrypt that information in transit using industry-standard Transport Layer Security (TLS) with a wildcard SSL and MD5 hash encryption technology. Still, we cannot guarantee the security of your personal information from unauthorized access, disclosure, use, or alteration. There is always a risk inherent in the electronic transmission and storage of information (including without limitation the risks of unauthorized entry or use, telecommunication issues, hardware or software failure, and other factors).

SOCIAL MEDIA ACTIVITIES AND LINKS TO OTHER WEBSITES
This Privacy Policy does not apply to information you provide to third parties whose applications or websites you access from links posted on our Site or App, including your social media accounts, and Company is not responsible for the privacy practices of these third party websites.
When you are on our Site or App, we may provide a link to another website or you could be directed to other websites that are beyond our control. For example, if you “click” on a banner advertisement, the “click” may take you off our Site and onto a different website. These other websites may send their own cookies to you, independently collect data or solicit personal information from you, and may or may not have their own published privacy policies. If you visit a website that is linked to our Site or App, you should consult that website’s privacy policy before providing any personal information. Also, if you connect with any of the social media activities available on our Site or App, such as the Facebook “Like” button, the social media platform controls these activities, not Company. The social media platform may collect your IP address, the page you are visiting on our Site or App, and may set a cookie to enable the activity to perform. The privacy policy of the social media platform governs how your personal information is handled when you interact with these activities.

CONSENT TO PROCESSING YOUR INFORMATION IN THE UNITED STATES
Company operates in the United States and follows the information and consumer protection laws of the United States and its individual states as applicable. If you reside or are located in a different country, the data protection laws of that country may differ as to how your personal information is protected. We want you to understand that when you provide your personal information to us, or we obtain it through our Site or App or other means, you will be transferring your information to the United States. In doing that, you are giving us your consent to process your information in the United States, in accordance with United States laws, and as explained in this Privacy Policy. We will respond to requests you may have about your personal information as described below.

MAKING REQUESTS ABOUT YOUR PERSONAL INFORMATION
If you contact us for any of the reasons listed below, we will make a prompt and commercially reasonable effort to honor your request:

  • To opt out of direct marketing communications;
  • To find out what personal information we have about you or request a readable copy;
  • To ask us to limit how we use your personal information;
  • To ask us to correct personal information we have about you;
  • To object to our further use of your personal information; and
  • To advise us about a complaint regarding how we handle your personal information.
  • To make a request about any of those matters, please contact us as described below.

HOW TO CONTACT US
Please contact us if you have any questions or requests about this Privacy Policy or how we process personal information, or if you want to opt-out of receiving our e-mail materials.
By e-mail: [email protected]
By letter: FarmaceuticalRx, LLC
2730 Sidney Street
Suite 300
Pittsburgh, PA 15203

We may need to confirm your identity in order to respond to some requests.

NOTIFICATION OF CHANGES TO THIS PRIVACY POLICY
If we make substantive changes to this Privacy Policy, we will notify you by posting the changes on the Site, and we may also contact you by e-mail if you are on our e-mail contact list.