Truveris Privacy Policy

Last Updated: August 1, 2016

Truveris understands how important the privacy of personal information is to the visitors of our Websites (as defined below) (“Visitors”) and clients who subscribe or use our Service Offerings (as defined below) (“Clients”), so we take your privacy very seriously.  We are committed to ensuring that any personal information shared with us on our website or through our services is protected and kept confidential in accordance with this Privacy Policy.

This Privacy Policy describes information we collect; how we collect; how we use, with whom we share; how we protect your information; your choices regarding the information collected; other information related to the privacy of your information; and how to contact us.  We encourage you to freely communicate with us about questions or concerns about this Privacy Policy.

This Privacy Policy applies to all existing and future Website(s), application(s), domain name(s), linked pages, features, content, products, services, mobile properties and mobile device applications for iPhone, iPad, Android or other smartphone or tablet device (each, a “Service Offering”) owned or operated by Truveris.  By visiting our Website(s) or using any of our Service Offerings, you hereby acknowledge and accept the terms and conditions set forth in this Privacy Policy, including without limitation, the use and disclosure of your information as outlined in this Privacy Policy.

In some circumstances, especially if you have provided your HIPAA Protected Health Information (“PHI”) to us, our use of your information will also be subject to the requirements of the Health Information Portability and Accountability Act (“HIPAA”).  For the purposes of this Privacy Policy, PHI shall have the same meaning as defined under HIPAA and be included in the definition of “personally identifiable information” or “PII” (as defined below).  To the extent any term(s) in this Privacy Policy conflict with any regulation under HIPAA, HIPAA regulations will control and supersede the terms in this Privacy Policy.

References to “Truveris” refer to Truveris Inc., including, if applicable, any entity that Truveris Inc. controls or is controlled by, including without limitation a parent or subsidiary, as applicable (“Related Entity”).  Truveris may share information among its Related Entities, or websites owned or controlled by a Related Entity, but information collected under this Privacy Policy is always protected under the terms of this Privacy Policy.

This Privacy Statement covers the information practices of all Truveris-owned or operated Websites that link to this Privacy Statement, including: https://www.truveris.com; https://www.rxchoice.com and other websites that may be added by Truveris at any time (each, a “Website”).

INFORMATION WE COLLECT

Information About You

We collect a variety of personally identifiable information (“PII”) about Visitors and Clients in order to ensure quality user experience. “PII” means information that we can use to identify or contact you, such as your name, address, telephone number, email address, health insurance plan information and PHI. You are responsible for ensuring the accuracy of all PII that you submit to Truveris. Inaccurate information may affect your experience when visiting our Website(s), using the Service Offerings and/or our ability to contact you as described in this Privacy Policy.

PII does not include “Aggregated Information” which is information or data we collect where the individual user identity has been removed. Aggregated Information helps us understand and analyze trends, user needs and other information to provide improvements to our Website(s) and Service Offerings.

We also collect “Non-Personal Information” when you visit our Website(s) or use our Service Offerings. “Non-Personal Information” means information that we cannot use to identify you. Non-Personal Information is not treated as PII unless we combine it with or link it to PII that you give to us.

Information About Others

You may have the opportunity to provide information about other individuals through our Website(s) or Service Offerings. If you give us PII for someone else, you must first obtain consent or have authority to consent for each such individual prior to providing his or her PII to us.

HOW WE COLLECT INFORMATION

We collect PII about you through a number of different ways when you visit our Website(s) or use our Service Offerings.

Information You Give Us

We collect PII that you give to us when you fill out a contact us form or the like on our Website, call or email us, register for an account under a Service Offering or otherwise use our Service Offerings.

Location Information

When you access our Website(s) or use our Service Offerings using a desktop or mobile device, you may be prompted to enter your location or give us your consent to access your location (“Location Information”).  If you use a mobile application for one of our Service Offerings, we may, with your consent, passively collect Location Information when our application is installed on your mobile device.  You can change the privacy settings of your mobile device at any time to stop sharing your Location Information with us.  Please note that certain features and functionality of the Service Offering may be affected or be unavailable if you do not share your Location Information with us.

Call Recording and Monitoring

Your calls to and from us may be recorded for various purposes including: monitoring customer service quality or compliance, checking accuracy of information you provide us, preventing fraud or providing training for our staff.  Any PII obtained from you during the call will be treated in accordance with the provisions of this Privacy Policy.

Information We Collect Automatically

Even if you do not provide any PII to us, we automatically collect certain information about your use and interaction with our Service Offerings.

For example, when you visit our Website(s), our systems automatically maintain web logs to record data about all visitors who use our Website and stores this information in our database.  These web logs may contain information about you including the following: IP address, type(s) of operating system you use, type of device you use, date and time you visited the Website, your activity and/or referring websites. We use your log information to troubleshoot problems, gather demographic information, customize your experience when accessing our Service Offerings and other business purposes.

Information Collected From Other Sources

We may receive information about you from outside sources and add or combine it with, your PII and/or Non-Personal Information, including information such as commercially available demographic or marketing information, which helps us provide better service to you and inform you of Service Offerings or other information that may be of interest to you.

How We Use Information Collected

We may use information we collect about you to:

  • Administer tools and functionality on our Website(s);
  • Administer and provide you with Service Offerings;
  • Provide you with access to other offerings;
  • Respond to your inquiries and send you administrative communications;
  • Obtain your feedback on our site and our Service Offerings;
  • Combine your information with other information, including without limitation, demographics, prescription drug pricing, or other Aggregated Information, for analysis, testing and other purposes;
  • Statistically analyze or measure user behavior, activity and industry trends for testing or other purposes that may help us improve our Service Offerings;
  • Provide you with related content, marketing and/or advertisements;
  • Conduct research on and/or analyze Accounts or Website activities; or
  • Send you personalized emails, offers, information and secure electronic messages pertaining to your Account, activities or related interests, including news, announcements, marketing, reminders and opportunities.

WITH WHOM DO WE SHARE INFORMATION

Disclosure With Your Consent

We may disclose your information with your advance consent to disclosure, which we may obtain in a number of ways, including:

  • In writing;
  • Verbally;
  • Online, by clicking on a link or button; or
  • Pushing buttons on a phone dial pad.

When applicable to fulfill a request related to your use of our Website(s) or our Service Offerings, we may share your PII with third parties to fulfill such request(s) with your consent.

We may share your information with third parties as necessary to provide administrative, technical, operational and/or maintenance support related to our Website(s) or our Service Offerings. We may also share information with our Related Entities, affiliates, agents, outside vendors or service providers to perform functions on our behalf.  When a third party acts solely on our behalf, we use our reasonable commercial efforts to require that party to follow the privacy practices stated in this Privacy Policy or have complementary privacy protections to protect your information. We do not share your information with unaffiliated third parties except as permitted to do so in this Privacy Policy.

Disclosure Without Your Consent

In general, we may disclose your information without your consent to disclosure when we reasonably believe disclosure is appropriate in order to:

  • Comply with the law (e.g., lawful subpoena or court order);
  • Cooperate with or report to law enforcement agencies in investigations that involve users who use our Website(s) or Service Offerings for activities that are or may be reasonably perceived as illegal or illegitimate activities;
  • Enforce or apply agreements that apply to our Website(s) or our Service Offerings; or
  • Enforce or protect our rights or property or that of our Related Entities and affiliates, including respective officers, directors, employees, agents, third-party content providers, suppliers, sponsors, or licensors (e.g., to address allegations about fraudulent or unlawful activity related to use of a Service Offering).

We may share your information between our Related Entities where it is necessary to support, improve, develop or otherwise provide the Website(s) or Service Offerings to you.

Disclosure Related to Business Events

Information about our Visitors and Clients, including PII, may be disclosed as part of a merger, acquisition, public offering or sale of Truveris’ assets. It may also be disclosed in the unlikely event of insolvency, bankruptcy, or receivership in which personally identifiable information would be transferred as one of the business assets of Truveris.

WHAT CHOICES DO YOU HAVE

Updating/Removing Your Personal Information

If you do not want your PII used by Truveris as provided in this Privacy Policy, you should immediately discontinue using the Website(s) and all Service Offerings, tools, applications or other materials offered by Truveris and cancel all of your accounts for Service Offerings that might exist.

If you provide us with your PII, we allow Visitors and Clients to easily adjust settings and manage the PII provided. You may correct or update any PII you have submitted at any time by Contacting Us.

If you have registered to receive Service Offerings and desire to delete all or some of the PII you have provided to us, please Contact Us to request deletion of your PII. Upon receiving your request, we will use our reasonable commercial efforts to delete your PII from our active databases, but please be aware that it may not be technologically possible to remove every record of the PII you have provided to us from our servers.

You can also customize how Truveris collects and uses your information as set forth below.  However, you should note that your decisions on how to customize the collection of your information may impact the functionality or availability of the Website(s) and/or Service Offerings.

To opt out of future marketing or other promotional communications from Truveris, you may click on the unsubscribe link at the bottom of any marketing or promotional emails or Contact Us.

HOW WE SECURE AND PROTECT INFORMATION

We use a variety of physical, administrative, electronic, technical and procedural safeguards to maintain a high-level of security to guard your PII, including without limitation, password protection, data backup, audit controls, access controls, and some data encryption. Specifically, we use commercially accepted procedures and systems to protect against unauthorized access to our systems. We restrict access to your PII to those employees, advisors and contractors who are covered by this Privacy Policy and need to know such information to provide services or otherwise assist you in connection with our Service Offerings. We protect the security of your PII during transmission via our Website by using industry standard Secure Sockets Layer (“SSL”) software, which encrypts information you input, so that no one else can read it as it is transmitted over the Internet.

We also urge you to take additional steps on your own to safeguard and maintain the integrity of your PII. For example, you should never share your login information for a Service Offering with other people and be sure to sign off when finished using a shared or public computer.  We urge you to be aware that if you use or access our Website(s) or Service Offerings through a third-party computer network (e.g., employer, internet café, library) or other potentially non-secure internet connection, such use is not recommended and solely at your own risk. It is your responsibility to check beforehand on the privacy and/or security policy of your network prior to accessing the Website(s) or Service Offerings.

We are not responsible for the handling, sharing, re-sharing and/or distribution of your information except as set forth in the Privacy Policy. Moreover, if you forward or submit any information electronically to another person or entity on or off the Website(s) or Service Offerings, even if you are linked via our Website(s) or Service Offerings, we are not responsible for any harm or other consequences from third party use or re-sharing of your information.  We recommend that you review all privacy and security policies of such third parties before you submit your information and all such disclosure is at your own risk.

COOKIES & WEB BEACONS

What Are Cookies & Web Beacons?

A cookie is a small data file that certain websites write to your computer hard drive when you visit the website(s).  These files identify your computer and record your preferences and other data about your visit to our Website(s) and/or websites you accessed before visiting our Service Offerings.

A web beacon is a tiny, often invisible graphic image displayed in a webpage, web-based document, or e-mail message. When the user’s web browser reads the code embedded in a web beacon, it can pass along the following information to us: IP address of the user’s computer or mobile device, date and time viewed, length of time viewed and type of browser used.  Web beacons can also be linked to a user’s cookies and any personally identifiable information that may be stored in them.

How Do We Use Cookies & Web Beacons?

Some cookies allow you to maintain continuity of navigation when viewing our Website(s) during one (1) online session (“Session Cookie”).  After closing the browser, a Session Cookie simply terminates and is not stored on your computer hard drive thereafter.

Other cookies are saved and stored on your computer hard drive, so we can customize your next visit to our Website(s) by saving your settings, preferences, drug information and other information collected in a prior session.  As a consequence, cookies are often tied to your PII when used by us.

We use information collected through cookies and/or web beacons as Aggregated Information to understand how our users use our Service Offerings, gauge traffic, troubleshoot and make adjustments to continually improve our Service Offerings.

We may also use cookies and/or web beacons for remarketing to advertise online.  Under these circumstances, we may place cookies and/or web beacons on your mobile devices or computer to allow third parties and their advertisers to feed advertisements to you based on the history of your past visits to our Website(s) or other websites.  Truveris is not responsible for the actions of cookies and/or web beacons from third party websites, which may require you to accept cookies and/or web beacons that collect information.

What Are My Choices For Cookies?

Your browser settings allow you to prevent accepting cookies from websites you visit. The default setting on most web browsers are set to accept cookies, but if you prefer not to receive cookies you can set your browser to warn you or refuse cookies all together by turning them off in your browser.  If you choose not to accept the use of cookies on our Website(s), your use of our Website(s) may be impaired or limited.  At this time we do not respond to browser ‘Do Not Track’ signals.

If at any point, you would like to clear browsing data including cookies from our Website(s), you may select ‘Clear Recent Searches” on your browser settings, but this data may continue to be saved in our database.

MISCELLANEOUS

Children

We are committed to protecting the privacy of children and are committed to preventing the unintentional collection of Personal Information and Protected Health Information from children under the age of 13 in accordance with the Children’s Online Privacy Protection Act.  Our Website(s) and Service Offerings are not designed or intended to attract children under the age of 18, and we do not knowingly allow individuals under the age of 18 to create accounts for our Service Offerings.  A parent or legal guardian, however, may use one of our Service Offerings on behalf of a minor in their custody, subject to the terms and conditions of the Service Offering.

If you are the parent or legal guardian of a child under the age of 13, and you have reason to believe that your child has provided his or her own PII to us, you have the right to request the removal of that child’s PII from our database. In order to request such removal, please contact us. You will be required to verify your identity and status as the child’s parent or legal guardian in order to have their PII removed.

External links

We do not control and are not responsible or liable for the security, authenticity, updates, accuracy of information, privacy policies, practices or otherwise of other websites or applications you might visit, interact with, or from which you might obtain services or products, even if you visit them using links from our Service Offerings.  The purpose of the external sites is to provide Visitors and Clients with further outside resources and information to potentially help our Visitors and Clients, which may or may not be related to Truveris

Using our Service Offerings from outside the United States

Please be aware that if you access our Website(s) or use our Service Offerings from outside the United States, your information may be transferred to, stored, and processed in the United States.  Also, certain features or services offered through the Service Offerings may be processed or administered from countries outside of the United States (e.g., offshore customer support).  Laws in countries outside of the United States may vary in regard to privacy, data, and other matters; but Truveris upholds United States law to protect your privacy. By using our Service Offerings, you understand that your information may be transferred to remote Truveris facilities and the third parties with whom we share it as described in this Policy.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy at any time as we deem appropriate with or without notice to you. In the event changes are made to this Privacy Policy, we will post the current version of our Privacy Policy on our Website and at other places we deem appropriate.  You understand and agree that your continued use of the Service Offerings shall be deemed as acceptance to any and all changes to this Privacy Policy.  You may also contact us to request a copy of our current Privacy Policy.

CONTACT US

If you have questions or concerns about this Privacy Policy, please contact us.  Please provide your name and contact information in your correspondence.

 BY POSTAL MAIL

Truveris, Inc.
Attn: Privacy Officer
2 Park Avenue, Suite 1500
New York, NY 10016

BY PHONE
(800) 430-1430

BY EMAIL
info@truveris.com

If you do not agree to the terms of this Privacy Policy, you must immediately close all Truveris Websites and exit from all Truveris Service Offerings.