Privacy and Security Policy

Last Updated: July 17, 2020

This Privacy Policy describes the information collected through your interactions with us including but not limited to, the website and mobile applications (“Applications”) (together, the “Services”) that we provide and how that information is used and shared. MedAvail Pharmacy Inc. and MedAvail Technologies Inc. (together, “SpotRx,” “SpotRx Pharmacy”, “we,” “us,” or “our”) and our suppliers may collect or receive the types of personal information described below in connection with your access to and use of the Services.

By accessing or using the Services or by accepting our Terms of Use, you agree that you have read and understand this Privacy Policy.

Privacy laws and guidelines are part of a constantly changing environment. We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. All changes will be effective immediately upon posting to our Services and Applications.  Material changes will be conspicuously posted or otherwise communicated to you. You are responsible for reviewing this Privacy Policy periodically to ensure that you are aware of our current privacy practices.

Data Security

SpotRx does not guarantee that loss, misuse, or alteration of personal information will not occur, but we have implemented reasonable physical, technical and administrative safeguards to protect personal information within our organization, and security measures in place to help protect against the loss, misuse, and alteration of information under our control. The storage and communication of information can never be completely secure, so we do not guarantee that communications or other information that you submit or that are otherwise provided to us will be completely secure. If you become aware of any breach of Services security or this Privacy Policy, please notify us in accordance with the “Contact Us” section below. If our security system is breached, we will notify you of the breach only if and to the extent required under applicable law.

We Collect Personal Information and Other Information You Submit

  • Protected Health Information (PHI)
  • Personal information
  • Account and profile information

Protected Health Information. To the extent that information collected through or received by the Services is Protected Health Information (“PHI”) as that term is defined under the Health Insurance Portability and Accountability Act of 1996 and any regulations promulgated thereunder (“HIPAA”), that information is governed by SpotRx’s Notice of Privacy Practices, and not this Privacy Policy. References to “Collected Information” in this Privacy Policy do not include PHI. To the extent the information collected through or received by the Services constitutes PHI, we will protect your PHI and will only use or disclose it as required or permitted by applicable federal and state laws, including HIPAA, and in accordance with any contractual obligations that we may have with your health care provider. It may be necessary for us to share your PHI with third parties, including suppliers that we engage to provide services in connection with Services. If we share your PHI with any third party, we will share only the minimum necessary information to enable the third party to provide the services for which we have engaged them in connection with the Services, and we will ensure that the third party agrees to use and disclose your PHI only as required or permitted by applicable federal and state laws, including HIPAA. For additional information about how we may use or disclose your PHI and your rights with respect to your PHI, please refer to our Notice of Privacy Practices.

Personal Information. We will collect any personal information from or about you that you choose to submit to us, which may include your name, email address, birth date, physical address, and telephone number. You will be required to provide personal information in order to use certain  Services, for example, to create a SpotRx account and profile and to submit an order for a new prescription, refill an existing SpotRx prescription or transfer a prescription from a different pharmacy. Specifically, we collect your personal information in connection with your account and your prescription orders and transfers, in receiving and fulfilling information requests, when you respond to communications from us and when you participate in sweepstakes, surveys or contests that we offer or administer  We will use your personal information as described below, including to process your orders for products, to communicate with you in connection with your orders, and to provide you with information and communications that you request or that we believe are relevant or may be of interest to you, subject to applicable laws and the terms of this Privacy Policy. If you choose not to provide your personal information, we may not be able to provide you with requested information or Services including prescription fulfillment.

Account and Profile Information. You will need to submit certain information in order to set up your SpotRx account and profile and will be required to establish a personal access code (PIN). To create an SpotRx account you will need to submit your email address and password. To create a profile within that account, you will need to submit your first and last name, date of birth, mobile number, and health insurance information. Through the online Services and the Applications, you may have the option of submitting an image of your health insurance information. If you request to fill a prescription using the online Services or Applications, you can do so by taking a picture of the label of the prescription.

You are responsible for maintaining the confidentiality of your PIN and any other personal information provided as a result of creating an account. If you choose to share your PIN or any other information you use in connection with the Services with a person who will manage your account on your behalf, you are responsible for all actions taken by such person with respect to the use of your account. SpotRx will assume that any modifications to your account and any requests made to SpotRx such as to fill, refill or transfer prescriptions, are being made by you on your behalf by an authorized individual.

Other Information We Collect

  • Data collected by the servers used to operate the Services (e.g., IP addresses)
  • Location information
  • Data collected by cookies

IP Addresses and Related Data. The Applications and the servers used to operate the Services may collect personal information pertaining to you and the equipment, software, and communication methods you use to access the Internet and the Services, including Internet protocol (“IP”) addresses assigned to your computer, your Internet service provider (ISP), your device ID, your approximate geographic location, your browser type, the pages you access on the Applications, the web sites you access before and after visiting the Services, the length of time you spend on the Services, date and time stamps, and clickstream data. We may use this information to administer the Services, to generate statistical information, to monitor and analyze Services traffic and usage patterns, to monitor and prevent fraud, to investigate complaints and violations of our policies, and to improve web site and Applications content and the products, services, materials, and other content that we describe or make available through the Services. We may combine this information with personal information, other collected information, and information obtained from third parties for security reasons. The suppliers that we use to provide the services including MedAvail may collect information about your visits and use of the Services.

Location Information. In addition to the approximate geographic location information collected as discussed above, we may access more specific location information with your consent in order to enhance your user experience and increase the usefulness of the Services. This includes both geographical location information that you input using the Services and geographical location information collected by device-based location services (including GPS data). You may choose to allow us to access your location by granting the Services access to your location when prompted or through your device’s location services settings. We may use various technologies to access your location, including GPS and IP addresses. We also use the Google Maps/Google Earth API(s). Pursuant to the Google Maps/Google Earth APIs Terms of Service, use of this location feature is also subject to Google’s privacy policy, which can be found at http://www.google.com/policies/privacy. Both the Google Maps/Google Earth APIs Terms of Service and the Google Privacy Policy are incorporated into this Privacy Policy by this reference.

Cookies. Through the use of cookies, we collect information about Services traffic and usage patterns and to facilitate and enhance the user experience on the Site. “Cookies” are small pieces of information that are stored on your computer’s hard drive by your browser. The Site may use both cookies that we implement and cookies implemented by our suppliers and other third parties. We use cookies to track how you access and use the web site, to learn when and how users visit the web site, to learn how popular web site pages are and aren’t, to learn which search terms are used to find the web site, and to learn which web sites direct you to the web site. We also use cookies to help display certain information on the web site and to improve your enjoyment of the web site. Most browsers automatically accept cookies. You can disable this function, but disabling cookies may impact your use and enjoyment of the web site. Our web site suppliers may use cookies and other tracking technologies, such as pixel tags, to track site visitors across the Internet to understand how you get to the site. Due to this automatic collection of cookies, we do not honor “do not track” requests.

Google Analytics. We use Google Analytics to collect and process information about your use of the website. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our website.

To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

 

How We Use and Share Collected Information

In addition to the uses described above, SpotRx and its suppliers may use and share personal information as described below. We will not sell, rent, or share personal information except as disclosed in this Privacy Policy or as permitted by applicable law.

  • We use personal information for the purpose for which it was collected.
  • We use personal information to send you text messages, in compliance with applicable law.
  • We use personal information to communicate with you.
  • We share personal information with the third-party service providers that provide us with services in connection with the Services.
  • We use personal information to evaluate and improve the Services.
  • We aggregate personal information to create anonymous data on Services users.
  • We may share personal information with our employees and affiliates who have a need to know the information for our business purposes.
  • We use and share personal information in connection with legal proceedings and to protect our rights.
  • We share personal information if SpotRx undergoes a change in control or in the event SpotRx changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction.

Purpose Collected. We will use your perrsonal information for the purpose for which it was collected, for example, to process your prescription orders, to transfer your prescriptions, to communicate with you in connection with your account, and to provide you with information and communications that you request. If you place an order through the Services, we will use personal information to communicate with you regarding your order. If you sign up for an SpotRx account, we will use personal information to communicate with you regarding your account. Your location information will be used to find our pharmacy self-serve kiosks near you. If you contact us for support or assistance in using the Services, we may use personal information to determine whether or not your system meets the minimum requirements needed to access and use the Services and otherwise to contact you regarding your request.

SpotRx Account Notification Alerts, Mobile Terms & Conditions.  Reply ENROLL to (844) 984-2125 to receive refill reminders and account notifications via text. Message frequency will vary according to account activity. Reply HELP for help, Reply BLOCK to cancel. Msg & Data Rates May Apply. Compatible carriers include: Associated Carrier Group (ACG), AT&T, Boost, ClearSky, Google Voice, Interop, Metro PCS, Peerless Network, Sprint, T-Mobile®, Truphone Limited, U.S. Cellular, Verizon Wireless, and Virgin Mobile. Alerts sent via SMS may not be delivered if the mobile phone is not in range of a transmission site, or if sufficient network capacity is not available at a particular time. Even within a coverage area, factors beyond the control of the wireless carrier may interfere with message delivery, including the customer’s equipment, terrain, proximity to buildings, foliage, and weather. The wireless carrier does not guarantee that alerts will be delivered and will not be liable for delayed or undelivered messages. To discontinue receiving SMS account notifications from SpotRx, text BLOCK to (844) 984-2125 or STOP to (226) 400-4481. For additional help, text HELP to (844) 984-2125 or contact support at info@spotrx.com or 844-477-6879.

Communication with You. We may use personal information to notify you of changes made to the Services (for example, changes to our Terms of Use and this Privacy Policy) and, if you sign up or otherwise opt-in to receive marketing and promotional communication from us, to send you marketing and promotional materials and other communications as described above. If you provide us with your telephone number, we may call you at that telephone number to conduct satisfaction surveys. and you consent to receiving text (SMS) messages from us at that telephone number. If you sign up or otherwise opt-in to receive notifications about your account and prescriptions including refill reminders via email and/or text (SMS) message in the Application’s settings, you acknowledge that email notifications will be sent to the email address you provide to us and the text messages will be sent to the telephone number you provide to us.  If you opt-in to receive email and/or text (SMS) message notifications about your account and prescriptions orders, such notifications may include limited personal information about your prescriptions, and whoever has access to your mobile phone, carrier account or email account will also be able to see this information.

Sharing Collected Information with Our Suppliers. We may share personal information with our Services management and hosting suppliers, data analytics providers, marketing and public relations service providers, text message service suppliers, email service suppliers, and other suppliers as necessary for us to provide the Services and our products and services to you and as may otherwise be permitted by applicable law. Our suppliers are authorized to and may use and disclose personal information as necessary for them to provide the applicable services to us.

Evaluation and Improvement of the Services. We may use personal information: to analyze, develop, and improve the content, materials, products, and services that we make available through the Services and the Services’ functionality; to inform marketing, and communication plans and strategies; to evaluate user needs and customize Services content, promotional emails, and your browsing experience; and for other legitimate and lawful business purposes.

Aggregate Data. We may aggregate personal information to create anonymous aggregate data on Services users, which describes users as a group but does not reveal the identity of individual users. We may use aggregate data to understand users’ needs, to determine user demographics and usage patterns, to determine which kinds of products and services we can provide, and to improve and enrich our products and services and the Services.

Security and Protection of Rights. We may use personal information and share it with third parties to the extent permitted by applicable law, including in the event of a subpoena, court order, or law enforcement request. We will use personal information and share it with third parties if we believe doing so is necessary to operate the Services or to protect our rights or the rights of others, including disclosing information necessary to identify, contact, or bring legal action in the event of a violation of our contracts, terms, or policies.

Business Transactions.  If SpotRx undergoes a change in control, acquisition, merger, reorganization, or asset sale, all information owned by or in the control of SpotRx may be transferred or sold to the successor of the transaction. That successor will be bound by this Privacy Policy as it applies to that information.

 

Retention of Personal Information

We will keep personal information for the period necessary to fulfill the purposes described in this Privacy Policy unless a longer retention period is permitted or required by law.

 

Third-Party Web Sites

The Services may link to, or be linked to, web sites not maintained or controlled by SpotRx. SpotRx is not responsible for the privacy policies or practices of any third parties or any third-party web sites or applications. This Privacy Policy does not apply to any third-party web sites, applications or to any personal or other information that you may provide to third parties. You should read the privacy policy for each web site and application that you visit.

Access by Children

The Services are not directed at children under 13 years of age. SpotRx does not knowingly collect or use information from children under 13 through the Services. If a parent or legal guardian becomes aware that their child has provided SpotRx with information without his or her consent, the parent or legal guardian should contact us using the contact information below. If we become aware that a child under 13 has provided us with information, we will delete that information from our files.

 

Access from Outside the United States

If you are visiting the Services from outside the United States, please be aware that personal information may be transferred to, stored in, and processed in the United States (where our and our suppliers’ servers and databases are located and operated).  Certain governmental authorities may not consider the level of protection of personal information in the United States to be equivalent to that required by the in other jurisdictions.

 

California Residents

Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your personal information within the past year for direct marketing purposes, and (b) a description of the categories of personal information disclosed, by emailing us at info@spotrx.com.

California’s “Do-Not-Track” Requirement.  we currently do not honor “do not track” requests. 

 

How to Access Your Personal Information

To access or update your personal information as it exists in our records, please contact us using the contact information below.

Contact Us: If you have any questions or concerns regarding this Privacy Policy, contact us by email at info@spotrx.com, by telephone at 1-844-477-6879, or by mail at 1430 E. Fort Lowell Rd., Suite 120, Tucson, AZ, 85719.

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