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CONSUMER DATA PRIVACY NOTICE
Vivunt Pharma LLC values your privacy and aims to inform you about how we gather, use, and share information. This Privacy Policy applies to the websites and applications managed by Vivunt Pharma LLC. and its affiliates, subsidiaries, successors, and brands (“Vivunt Pharma”, “we”, “us”, or “our”). It details our practices regarding information collected through the website you are currently accessing (referred to as the “Service”). By providing personal information or using the Service, you acknowledge that you have read and understand this Privacy Policy.
USE BY MINORS
We ask that individuals under the age of 16 do not provide personal information through the Service. If your child has provided personal information and you wish to have it removed, please contact us as detailed under “Contacting Us”.
INFORMATION COLLECTION
We collect personal information you provide to us, such as when you subscribe to newsletters, request tips, or process orders, and participate in activities like sweepstakes or promotions. Required and optional information will be indicated.
We may combine the information you provide with other data collected from you through Vivunt Pharma affiliates, both online and offline, such as your purchase history. We may also combine it with publicly available information and data from third-party providers.
We also gather personal information as outlined in the “AUTOMATIC INFORMATION COLLECTION AND USE” section below.
If you provide personal information about another person, you must have the authority to do so and allow us to use it according to this Privacy Policy.
SENSITIVE INFORMATION
Unless specifically requested, please do not send or disclose sensitive personal information (e.g., Social Security numbers, information on race, ethnicity, political opinions, religion, health, sexual life, criminal background, trade union membership, or biometric/genetic data) through the Service or otherwise. We may infer health information from your use of the Service and provided data, which will be used as described in this Privacy Policy and our CHD Privacy Notice, including for interest-based advertising on the Service and third-party websites.
AUTOMATIC INFORMATION COLLECTION AND USE
We and our service providers may automatically collect certain information as you navigate the Service. For detailed information on cookies and tracking technologies used, please refer to the Cookie Policy. Except where permitted by law, cookies are placed only after receiving your consent through the cookie banner or preference center. The Cookie Policy also explains how to disable these technologies.
We and our service providers may also automatically collect and use information in additional ways.
Through your browser:
Most browsers collect certain information automatically, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, and Internet browser type and version. If you access the Service via a mobile device, we may collect similar information, including device type and identifier. This information helps us ensure that the Service functions correctly.
Using cookies:
Cookies are data files stored on your computer. They allow us to gather information such as browser type, time spent on the Service, pages visited, and language preferences. We and our service providers use this data for security, navigation, effective display of information, and personalizing your experience on the Service. Cookies also help us recognize your device, making your use of the Service more convenient, like remembering your shopping cart contents. Additionally, cookies provide statistical data to improve the Service’s design and functionality, understand usage patterns, and resolve issues. They also help us tailor advertisements or offers to your interests. You can refuse cookies by following your browser’s instructions, but doing so may affect your experience on the Service. For more on cookies, visit [All About Cookies](https://www.allaboutcookies.org).
Using Flash cookies:
Adobe Flash technology (including Flash Local Stored Objects or Flash LSOs) helps us provide tailored information, facilitate your ongoing access to the Service, and collect and store information about your usage. If you prefer not to have Flash LSOs on your computer, adjust your Flash player settings using the Website Storage Settings Panel or Global Storage Settings Panel. Restricting Flash LSOs might limit the functionality of some Flash applications.
Using pixel tags, web beacons, clear GIFs, or other similar technologies:
These technologies may be used on some Service pages and in HTML-formatted email messages to track user actions, measure the effectiveness of our marketing campaigns, and compile Service usage statistics.
Interest-based advertising:
We may work with third-party advertising companies to show you ads for goods and services that may interest you when you access and use the Service and other online services. These third parties, like Google or Meta, may use cookies, web beacons, pixels, and other storage technologies to collect or receive information from our Service and elsewhere on the Internet to create targeted ads and measure their effectiveness.
IP address:
Your IP address is a number automatically assigned to your computer by your Internet Service Provider. It is logged in our server files whenever you visit the Service, along with the time of visit and pages viewed. This is standard practice for many online services. We use IP addresses to calculate usage levels, diagnose server issues, and administer the Service. Your approximate location can also be derived from your IP address.
Device Information:
We may collect data about your mobile device, such as a unique identifier, to understand how you use the Service.
DO NOT TRACK
The Service currently does not respond to Do Not Track (DNT) requests. DNT is a browser setting that indicates you do not want your web activity tracked across websites. For more details on DNT and how to enable it, visit [Do Not Track](http://www.donottrack.us).
HOW WE USE AND DISCLOSE INFORMATION
We use and disclose the information you provide as described at the point of collection. Refer to the “Choices and Access” section to learn how you can opt out of certain uses and disclosures.
When required by law, we will obtain your consent for using your personal information at the time of collection. We may also use your information to perform a contract, comply with legal obligations (such as pharmacovigilance), or for legitimate business interests. Specifically, we use information for:
Providing the functionality of the Service and fulfilling your requests:
- To provide the Service’s functionality and customer service.
- To respond to inquiries and fulfill requests, such as sending documents or email alerts.
- To send important information about our relationship or the Service, including changes to terms, policies, and other administrative details.
These activities help manage our contractual relationship with you and comply with legal obligations.
Accomplishing our business purposes:
- For data analysis to improve Service efficiency.
- For audits to verify compliance with legal, regulatory, or contractual requirements.
- For fraud and security monitoring to detect and prevent Cyber attacks or identity theft.
- For developing new products and services.
- For enhancing, improving, or modifying our Service or products.
- For identifying usage trends to understand which parts of the Service are most interesting to users.
- For determining the effectiveness of promotional campaigns and adapting them to users' needs and interests.
These activities are carried out to manage our contractual relationship with you, comply with legal obligations, and because we have a legitimate interest.
Analysis of Personal Information to provide personalized services:
We use your personal information to better understand you, enabling us to personalize our interactions and provide you with information and offers that match your interests. Additionally, we use this information to tailor content on the Service to your preferences. Personalized services are provided with your consent or based on our legitimate interests.
Disclosure of Information:
We may share information collected through the Service, including data collected passively as described in the “Automatic Information Collection and Use” section:
- To third-party partners with whom we offer cobranded or comarketed promotions.
- To advertising partners to personalize and serve advertisements on the Service and other websites and applications.
- To third-party service providers who offer services such as website and mobile application hosting, data analysis, website analytics, digital advertising, payment processing, order fulfillment, infrastructure provision, IT services, customer service, email and direct mail delivery, auditing, and legal services.
We may also share your information with third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of our business, assets, or stock, including bankruptcy proceedings.
Additionally, we may use and disclose your information as necessary or appropriate:
- To comply with legal processes or applicable laws, including laws outside your country of residence.
- To respond to requests from public and government authorities, including those outside your country of residence.
- To enforce our terms and conditions.
- To protect our rights, privacy, safety, or property, as well as that of our affiliates, you, or others.
We may use and disclose information collected automatically as described in the “Automatic Information Collection and Use” section. Where permitted by law, we may also use and disclose non-personally identifiable information for any purpose. If we combine non-personally identifiable information with identifiable information, we will treat the combined data as personal information.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your personal information:
How to opt out of direct marketing communications:
You can choose how we use and disclose your personal information for direct marketing through email, text, or mail. If you no longer wish to receive marketing communications from us, you can opt out by contacting us as described in the “Contacting Us” section. Please provide your name, the type of marketing communications you no longer wish to receive, and the relevant addresses. For instance, if you do not wish to receive marketing emails or direct mail, specify this and provide your email or postal address. You can also opt out by updating your online profile on the Service or by following the unsubscribe instructions in any marketing email.
We will endeavor to process your opt-out request as soon as reasonably possible. Note that opting out will not remove your personal information from the databases of affiliates with whom we have already shared your data as of the date we implement your request. Also, opting out of marketing communications will not affect the receipt of important transactional and administrative messages, from which you cannot opt out.
How to exercise your data rights:
Depending on your state of residence, you may have certain rights regarding your personal information. Details about these rights are provided in the State Supplemental Privacy Notice. You can exercise your data rights under relevant US State Privacy Law by clicking [by contacting us as described in the “Contacting Us” section below. While we will make reasonable efforts to accommodate your request, we may impose certain restrictions or requirements as allowed or required by law. You can also update your online profile on the Service, if available.
Crossborder Transfer:
Your personal information may be stored and processed in any country where we have facilities or service providers. By using our Service or providing consent (when required by law), your information may be transferred to countries outside of your residence, where data protection rules may differ. However, we have put in place appropriate contractual and other measures to protect personal information when transferred to our affiliates or third parties in other countries.
Security:
We implement reasonable organizational, technical, and administrative measures to protect personal information under our control. However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you believe your interaction with us is no longer secure (e.g., if you feel that the security of any account you have with us has been compromised), please notify us immediately as outlined in the “Contacting Us” section below.
Retention Period:
We retain your personal information for as long as needed or permitted based on the purpose(s) for which it was collected. Criteria for determining retention periods include: (i) the duration of our ongoing relationship with you and the provision of the Service; (ii) any legal obligations we are subject to; and (iii) whether retention is advisable in light of our legal position (e.g., statutes of limitations, litigation, or regulatory investigations).
Third-Party Sites and Services:
The Service may contain links to third-party sites and online services. This Privacy Policy does not cover, and we are not responsible for, the privacy or information practices of any third parties, including any third party operating any site or online service linked to or accessible from this Service. The inclusion of a link to a third-party site or service does not imply our endorsement or that of our affiliates.
Contacting Us:
Vivunt Pharma LLC., located at 3350 SW 148th Ave, Miramar, FL 33027, is responsible for the collection, use, and disclosure of personal information under this Privacy Policy.
If you are in the United States and wish to exercise your data privacy rights (as described in the “Choices and Access” section above), please submit a privacy request.
For other questions about this Privacy Policy, you can contact us through one of the following methods:
- On the Service: Via the Contact Us page
- By Phone: (754) 274-6949 (for Consumers and Professionals in the US)
- By Email: support@Vivunt.com
- By Mail: Consumer Care Center, Vivunt Pharma LLC., located at 3350 SW 148th Ave, Miramar, FL 33027.
Updates to This Privacy Policy:
We may update this Privacy Policy periodically to reflect changes to our practices or for other operational, legal, or regulatory reasons.
- Identifiers: such as name, alias, online identifiers, account name, physical characteristics or description.
- Contact and Financial Information: including phone number, address, email address, financial information, medical information, health insurance information.
- Characteristics of Protected Classifications: under state or federal law, such as age, gender, race, physical or mental health conditions, and marital status.
- Commercial Information: such as transaction information, payment information, tax withholding information, and purchase history.
- Biometric Information.
- Internet or Other Electronic Network Activity Information: such as browsing history, search history, and interactions with our Service or advertisements.
- Geolocation Data: such as device location.
- Audio, Electronic, Visual and Similar Information: such as call and video recordings.
- Professional or Employment-Related Information: such as specialty, education history, professional qualifications, work history, and prior employer.
- Inferences Drawn from Personal Information: to create a profile or summary about an individual’s preferences and characteristics.
- Sensitive Personal Information:
C. Purposes for Collecting Personal Information
We collect, use, and disclose Personal Information for the purposes described in our Vivunt US Privacy Policy, which include:
- Providing the Service and fulfilling your requests;
- Accomplishing our business purposes, including data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving, or modifying our Service, identifying usage trends, and determining the effectiveness of our promotional campaigns.
D. Your Data Privacy Rights
Depending on your state of residence, you may have the right to:
- Access and obtain a copy of your Personal Information.
- Delete your Personal Information.
- Correct inaccuracies in your Personal Information.
- Opt-out of certain processing activities, such as targeted advertising, the sale of Personal Information, or profiling.
- Appeal a decision we have made regarding your data subject request.
To exercise your data privacy rights, please submit a privacy request [here](#) or contact us as described in the “Contacting Us” section below. We will respond to your request in accordance with applicable law. If available, you may also visit the Service to update your online profile.
E. Privacy Notice for Nevada Residents
Under Nevada law, certain Nevada consumers may opt-out of the sale of “personally identifiable information” (as defined by Nevada law) to unaffiliated parties. If you are a Nevada consumer who wishes to exercise this right, please submit a request [here](#) or contact us as described in the “Contacting Us” section below.
F. Updates to this Supplemental Notice
We may update this Supplemental Notice periodically to reflect changes to our practices or for other operational, legal, or regulatory reasons.
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Contacting Us:
If you have any questions about this Privacy Policy, please contact us via one of these methods:
- On the Service: Via the Contact Us page
- By Phone: (754) 274-6949 (for Consumers and Professionals in the US)
- By Email: support@Vivunt.com
- By Mail: Consumer Care Center, Vivunt Pharma LLC., located at 3350 SW 148th Ave, Miramar, FL 33027.
- Social security, driver’s license, state identification card, or passport number
- Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
- Precise geolocation
- Racial or ethnic origin, religious or philosophical beliefs, or union membership
- Genetic data
- Biometric data processed for the purpose of uniquely identifying a consumer
- Personal Information collected and analyzed concerning a consumer’s health
- Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation
### C. Retention of Personal Information
We retain your Personal Information for the period reasonably necessary to provide goods and services to you and for the period reasonably necessary to support our business operational purposes listed in Section E.
### D. Categories of Personal Information We Disclose to Vendors & Third Parties
We may disclose any of the following categories of Personal Information among our affiliates and to Vendors and Third Parties:
- Identifiers: such as name, alias, online identifiers, account name, physical characteristics or description.
- Contact and Financial Information: including phone number, address, email address, financial information, medical information, health insurance information.
- Characteristics of Protected Classifications: under state or federal law, such as age, gender, race, physical or mental health conditions, and marital status.
- Commercial Information: such as transaction information, payment information, tax withholding information, and purchase history.
- Biometric Information.
- Internet or Other Electronic Network Activity Information: such as browsing history, search history, and interactions with our Service or advertisements.
- Geolocation Data: such as device location.
- Audio, Electronic, Visual and Similar Information: such as call and video recordings.
- Professional or Employment-Related Information: such as specialty, education history, professional qualifications, work history, and prior employer.
- Inferences Drawn from Personal Information: to create a profile or summary about an individual’s preferences and characteristics.
- Sensitive Personal Information: including:
- Social security, driver’s license, state identification card, or passport number.
- Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
- Precise geolocation.
- Racial or ethnic origin, religious or philosophical beliefs, or union membership.
- Genetic data.
- Biometric data processed for the purpose of uniquely identifying a consumer.
- Personal Information collected and analyzed concerning a consumer’s health.
- Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation.
---
Contacting Us:
If you have any questions about this Privacy Policy, please contact us via one of these methods:
- On the Service: Via the Contact Us page
- By Phone: (754) 274-6949 (for Consumers and Professionals in the US)
- By Email: support@Vivunt.com
- By Mail: Consumer Care Center, Vivunt Pharma LLC., located at 3350 SW 148th Ave, Miramar, FL 33027.
- Operating, managing, and maintaining our business.
- Responding to your inquiries and fulfilling your requests.
- Sending you important information regarding our relationship with you or regarding our Service, changes to our terms, conditions, and policies, and/or other administrative information.
- Conducting audits to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements.
- Preventing fraud or crime and for risk and technical security monitoring purposes.
- Facilitating the development of new products and services.
- Enhancing, improving, or modifying our Service or products and services.
- Performing research, analytics, and data analysis.
- Determining the effectiveness of our promotional campaigns to adapt our campaigns to the needs and interests of our users.
- Personalizing, advertising, and marketing our products and services.
- Complying with law, legal process, and internal policies.
- Maintaining records.
- Exercising and defending legal claims.
- Otherwise accomplishing our business purposes and objectives.
### G. Purposes for Processing Sensitive Personal Information
We, and our Vendors, collect and process the Sensitive Personal Information described in this Supplemental Notice to:
- Provide goods and services to you.
- Support our business operational purposes listed above.
- Facilitate transactions and payments.
- Comply with applicable laws and regulations.
- Conduct security and fraud prevention activities.
- Improve and develop our products and services.
- Support internal research and analysis.
- Manage and maintain our customer relationships.
- Respond to and support customer service inquiries and requests.
- Perform audits and risk assessments.
- Protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
- Handle and respond to legal claims and regulatory inquiries.
### H. Privacy Rights
California, Colorado, Virginia, Utah, Connecticut, Montana, Texas, and Oregon consumers have certain privacy rights under the US State Privacy Laws. These rights include:
- Right to Know: You have the right to request that we disclose the categories and specific pieces of Personal Information we have collected about you, the sources from which we collected the information, the purposes for which we collected the information, and the categories of third parties with whom we share Personal Information.
- Right to Delete: You have the right to request that we delete any Personal Information we have collected from you, subject to certain exceptions.
- Right to Correct: You have the right to request that we correct inaccurate Personal Information we maintain about you.
- Right to Opt Out: You have the right to opt out of the sale of your Personal Information, the sharing of your Personal Information for targeted advertising purposes, and the processing of your Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects.
- Right to Non-Discrimination: You have the right to be free from discrimination for exercising any of your privacy rights.
To exercise these rights, please submit a privacy request using one of the methods listed in the “Contacting Us” section of this Privacy Policy.
### I. Privacy Notice for Nevada Residents
Under Nevada law, Nevada residents may opt out of the sale of certain types of Personal Information. Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to the contact information provided in the “Contacting Us” section.
### J. Updates to this Supplemental Notice
We may update this Supplemental Notice from time to time in order to reflect changes to our practices, the law, or other regulatory requirements. We encourage you to review this Supplemental Notice periodically to remain informed about how we collect, use, and disclose your Personal Information.
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Contacting Us:
If you have any questions about this Supplemental Notice, please contact us via one of these methods:
- On the Service: Via the Contact Us page
- By Phone: (754) 274-6949 (for Consumers and Professionals in the US)
- By Email: support@Vivunt.com
- By Mail: Consumer Care Center, Vivunt Pharma LLC., located at 3350 SW 148th Ave, Miramar, FL 33027.
Sensitive personal data includes:
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Personal details that disclose:
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Social security number, driver’s license number, state ID card number, or passport number.
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Account log-in information, financial account numbers, debit or credit card numbers, along with any necessary security or access codes, passwords, or credentials for account access.
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Exact geolocation data.
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Information on racial or ethnic background, religious or philosophical beliefs, or union membership.
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Genetic information.
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Biometric data used for unique consumer identification.
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Personal information gathered and evaluated regarding a consumer’s health.
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Personal information gathered and evaluated concerning a consumer’s sexual life or sexual orientation.
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E. Sale and Sharing for Targeted Advertising:
We may share your Personal Information with trusted partners, including third parties that provide us with website analytics and digital advertising services. This may fall under the broad definitions of “sale,” “share,” or “targeted advertising” according to applicable US Privacy Laws. In these arrangements, the use of the shared information is restricted by policies, contracts, or similar limitations. We do not share, sell, or process for targeted advertising the Personal Information of children under 16 years of age.
F. Sources from Which We Collect Personal Information
We gather Personal Information directly from consumers in California, Colorado, Virginia, Utah, Connecticut, Montana, Texas, and Oregon, as well as from our affiliates, business partners, joint marketing partners, public databases, demographic data providers, publications, professional organizations, social media platforms, caregivers, third-party information providers, affiliates with whom you have a business relationship, vendors with whom we have contractual relationships and to whom you have provided your personal information, cookies and other tracking technologies, and third parties that share information with us.
G. Purposes for Processing Personal Information
We, along with our Vendors, collect and process the Personal Information (excluding Sensitive Personal Information) detailed in this Supplemental Notice to:
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Operate, manage, and maintain our business.
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Respond to your inquiries and fulfill your requests.
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Send you important information about our relationship with you or our Service, including changes to terms, conditions, and policies.
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Conduct audits to ensure our internal processes function as intended and comply with legal, regulatory, or contractual requirements.
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Prevent fraud or crime, and for risk and technical security monitoring.
-
Facilitate the development of new products and services.
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Enhance, improve, or modify our Service or products and services.
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Perform research, analytics, and data analysis.
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Assess the effectiveness of our promotional campaigns to tailor them to the needs and interests of our users.
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Personalize, advertise, and market our products and services.
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Comply with legal processes and internal policies.
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Maintain records.
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Exercise and defend legal claims.
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Achieve our business purposes and objectives.
We, along with our Vendors, collect and process the Sensitive Personal Information detailed in this Supplemental Notice for:
E. Sale and Sharing for Targeted Advertising:
We may share your Personal Information with trusted partners, including third parties that provide us with website analytics and digital advertising services. This may fall under the broad definitions of “sale,” “share,” or “targeted advertising” according to applicable US Privacy Laws. In these arrangements, the use of the shared information is restricted by policies, contracts, or similar limitations. We do not share, sell, or process for targeted advertising the Personal Information of children under 16 years of age.
F. Sources from Which We Collect Personal Information
We gather Personal Information directly from consumers in California, Colorado, Virginia, Utah, Connecticut, Montana, Texas, and Oregon, as well as from our affiliates, business partners, joint marketing partners, public databases, demographic data providers, publications, professional organizations, social media platforms, caregivers, third-party information providers, affiliates with whom you have a business relationship, vendors with whom we have contractual relationships and to whom you have provided your personal information, cookies and other tracking technologies, and third parties that share information with us.
G. Purposes for Processing Personal Information
We, along with our Vendors, collect and process the Personal Information (excluding Sensitive Personal Information) detailed in this Supplemental Notice to:
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Operate, manage, and maintain our business.
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Respond to your inquiries and fulfill your requests.
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Send you important information about our relationship with you or our Service, including changes to terms, conditions, and policies.
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Conduct audits to ensure our internal processes function as intended and comply with legal, regulatory, or contractual requirements.
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Prevent fraud or crime, and for risk and technical security monitoring.
-
Facilitate the development of new products and services.
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Enhance, improve, or modify our Service or products and services.
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Perform research, analytics, and data analysis.
-
Assess the effectiveness of our promotional campaigns to tailor them to the needs and interests of our users.
-
Personalize, advertise, and market our products and services.
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Comply with legal processes and internal policies.
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Maintain records.
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Exercise and defend legal claims.
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Achieve our business purposes and objectives.
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Provide the goods and services reasonably expected by an average consumer who requests them.
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Ensure security and integrity, using consumer Personal Information as reasonably necessary and proportionate for these purposes.
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Perform services on our behalf, including maintaining or servicing accounts, providing customer service, processing orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or similar services.
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Verify or maintain the quality or safety of a service or device that we own, manufacture, or control, and to improve, upgrade, or enhance the service or device.
We, along with our Vendors, collect and process the Sensitive Personal Information detailed in this Supplemental Notice for:
E. Sale and Sharing for Targeted Advertising:
We may share your Personal Information with trusted partners, including third parties that provide us with website analytics and digital advertising services. This may fall under the broad definitions of “sale,” “share,” or “targeted advertising” according to applicable US Privacy Laws. In these arrangements, the use of the shared information is restricted by policies, contracts, or similar limitations. We do not share, sell, or process for targeted advertising the Personal Information of children under 16 years of age.
F. Sources from Which We Collect Personal Information
We gather Personal Information directly from consumers in California, Colorado, Virginia, Utah, Connecticut, Montana, Texas, and Oregon, as well as from our affiliates, business partners, joint marketing partners, public databases, demographic data providers, publications, professional organizations, social media platforms, caregivers, third-party information providers, affiliates with whom you have a business relationship, vendors with whom we have contractual relationships and to whom you have provided your personal information, cookies and other tracking technologies, and third parties that share information with us.
G. Purposes for Processing Personal Information
We, along with our Vendors, collect and process the Personal Information (excluding Sensitive Personal Information) detailed in this Supplemental Notice to:
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Operate, manage, and maintain our business.
-
Respond to your inquiries and fulfill your requests.
-
Send you important information about our relationship with you or our Service, including changes to terms, conditions, and policies.
-
Conduct audits to ensure our internal processes function as intended and comply with legal, regulatory, or contractual requirements.
-
Prevent fraud or crime, and for risk and technical security monitoring.
-
Facilitate the development of new products and services.
-
Enhance, improve, or modify our Service or products and services.
-
Perform research, analytics, and data analysis.
-
Assess the effectiveness of our promotional campaigns to tailor them to the needs and interests of our users.
-
Personalize, advertise, and market our products and services.
-
Comply with legal processes and internal policies.
-
Maintain records.
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Exercise and defend legal claims.
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Achieve our business purposes and objectives.
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Provide the goods and services reasonably expected by an average consumer who requests them.
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Ensure security and integrity, using consumer Personal Information as reasonably necessary and proportionate for these purposes.
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Perform services on our behalf, including maintaining or servicing accounts, providing customer service, processing orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or similar services.
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Verify or maintain the quality or safety of a service or device that we own, manufacture, or control, and to improve, upgrade, or enhance the service or device.
We, along with our Vendors, collect and process the Sensitive Personal Information detailed in this Supplemental Notice for:
E. Sale and Sharing for Targeted Advertising:
We may share your Personal Information with trusted partners, including third parties that provide us with website analytics and digital advertising services. This may fall under the broad definitions of “sale,” “share,” or “targeted advertising” according to applicable US Privacy Laws. In these arrangements, the use of the shared information is restricted by policies, contracts, or similar limitations. We do not share, sell, or process for targeted advertising the Personal Information of children under 16 years of age.
F. Sources from Which We Collect Personal Information
We gather Personal Information directly from consumers in California, Colorado, Virginia, Utah, Connecticut, Montana, Texas, and Oregon, as well as from our affiliates, business partners, joint marketing partners, public databases, demographic data providers, publications, professional organizations, social media platforms, caregivers, third-party information providers, affiliates with whom you have a business relationship, vendors with whom we have contractual relationships and to whom you have provided your personal information, cookies and other tracking technologies, and third parties that share information with us.
G. Purposes for Processing Personal Information
We, along with our Vendors, collect and process the Personal Information (excluding Sensitive Personal Information) detailed in this Supplemental Notice to:
-
Operate, manage, and maintain our business.
-
Respond to your inquiries and fulfill your requests.
-
Send you important information about our relationship with you or our Service, including changes to terms, conditions, and policies.
-
Conduct audits to ensure our internal processes function as intended and comply with legal, regulatory, or contractual requirements.
-
Prevent fraud or crime, and for risk and technical security monitoring.
-
Facilitate the development of new products and services.
-
Enhance, improve, or modify our Service or products and services.
-
Perform research, analytics, and data analysis.
-
Assess the effectiveness of our promotional campaigns to tailor them to the needs and interests of our users.
-
Personalize, advertise, and market our products and services.
-
Comply with legal processes and internal policies.
-
Maintain records.
-
Exercise and defend legal claims.
-
Achieve our business purposes and objectives.
-
Provide the goods and services reasonably expected by an average consumer who requests them.
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Ensure security and integrity, using consumer Personal Information as reasonably necessary and proportionate for these purposes.
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Perform services on our behalf, including maintaining or servicing accounts, providing customer service, processing orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or similar services.
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Verify or maintain the quality or safety of a service or device that we own, manufacture, or control, and to improve, upgrade, or enhance the service or device.
We, along with our Vendors, collect and process the Sensitive Personal Information detailed in this Supplemental Notice for:
H. Categories of Entities to Whom We Disclose Personal Information
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Affiliates:
We may disclose your Personal Information, including Sensitive Personal Information, to our affiliates for the purposes described in this Privacy Policy. A list of our affiliates is available here – access Vivunt’s subsequent filings with the Securities Exchange Commission. Vivunt Pharma LLC. is responsible for managing the jointly used Personal Information. -
Vendors:
Our Vendors provide services for our websites, including this Service, as well as other products and services such as web hosting, mobile application hosting, data analysis, payment processing, order fulfillment, customer service, infrastructure provision, IT services, email and direct mail delivery services, auditing, legal services, and other similar services. -
Third Parties:
We may disclose your Personal Information to the following categories of Third Parties:-
At Your Direction: We may disclose your Personal Information to any Third Party with your consent or at your direction.
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Business Transfers or Assignments: We may disclose your Personal Information to other entities as reasonably necessary to facilitate a reorganization, merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
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Third Party Co-Branding and Co-Marketing Partners: We may share your Personal Information with third-party partners with whom we offer a co-branded or co-marketed promotion.
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Third-Party Advertising Partners: To improve the effectiveness of our communication and marketing campaigns, we may share data with our third-party advertising partners, including social media, medical journals, and publishers.
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Legal and Regulatory: We may disclose your Personal Information to government authorities, including regulatory agencies and courts, as reasonably necessary for our business operational purposes, to assert and defend legal claims, and otherwise as permitted or required by law.
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I. Data Subject Rights
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Exercising Data Subject Rights:
Consumers in California, Colorado, Virginia, Utah, Connecticut, Montana, Texas, and Oregon have certain rights regarding the collection and use of their Personal Information. These rights vary by state. As required by US State Privacy Laws, detailed information on data subject rights available to these consumers is provided below.
You can exercise your data subject rights under the applicable US State Privacy Law by clicking here or contacting us at 800-361-8068. While we will make reasonable efforts to accommodate your request, we reserve the right to impose certain restrictions or requirements, as allowed or required by applicable law.
Consumers in some states may also authorize an agent to make data subject requests on their behalf. -
Verification of Data Subject Requests:
We may ask you to provide information to verify your identity to comply with your data subject request. Specifically, when a California or Connecticut consumer authorizes an agent to make a request on their behalf, we may require the agent to provide proof of signed permission from the consumer, or we may require the consumer to verify their identity or confirm they provided the agent with permission. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request in accordance with applicable law. -
Non-Discrimination:
We will not discriminate against you for exercising your data subject rights. For example, we will not deny goods or services, charge different prices or rates, or provide a different level of quality for products or services as a result of exercising your data subject rights. -
Appeals:
To appeal our decision on your data subject requests, you may click here. Please enclose a copy of or reference our decision on your data subject request so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.
Data Subject Rights Disclosure
H. Categories of Entities to Whom We Disclose Personal Information
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Affiliates:
We may disclose your Personal Information, including Sensitive Personal Information, to our affiliates for the purposes described in this Privacy Policy. -
Vendors:
Our Vendors provide services for our websites, including this Service, as well as other products and services such as web hosting, mobile application hosting, data analysis, payment processing, order fulfillment, customer service, infrastructure provision, IT services, email and direct mail delivery services, auditing, legal services, and other similar services. -
Third Parties:
We may disclose your Personal Information to the following categories of Third Parties:-
At Your Direction: We may disclose your Personal Information to any Third Party with your consent or at your direction.
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Business Transfers or Assignments: We may disclose your Personal Information to other entities as reasonably necessary to facilitate a reorganization, merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
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Third Party Co-Branding and Co-Marketing Partners: We may share your Personal Information with third-party partners with whom we offer a co-branded or co-marketed promotion.
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Third-Party Advertising Partners: To improve the effectiveness of our communication and marketing campaigns, we may share data with our third-party advertising partners, including social media, medical journals, and publishers.
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Legal and Regulatory: We may disclose your Personal Information to government authorities, including regulatory agencies and courts, as reasonably necessary for our business operational purposes, to assert and defend legal claims, and otherwise as permitted or required by law.
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I. Data Subject Rights
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Right to Deletion:
You may request that we delete any Personal Information about you that we collected from you or other sources. -
Right to Correction:
You may request that we correct any inaccurate Personal Information we maintain about you. -
Right to Know:
You may request that we confirm whether we are processing your Personal Information, including Sensitive Personal Information, and provide you with the following information about how we have handled your Personal Information:-
The categories of Personal Information we collected about you;
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The categories of sources from which we collected such Personal Information;
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The business or commercial purpose for collecting Personal Information about you;
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The categories of Personal Information about you that we shared or disclosed and the categories of Third Parties with whom we shared or disclosed such Personal Information; and
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The specific pieces of Personal Information we have collected about you.
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Right to Receive Information About Onward Disclosures:
You may request that we disclose to you:-
The categories of Personal Information that we have collected about you;
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The categories of Personal Information that we have sold or shared about you and the categories of Third Parties to whom the Personal Information was sold or shared; and
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The categories of Personal Information we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
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Right to Non-Discrimination:
You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights. -
Right to Restrict or Limit the Use of Sensitive Personal Information:
For California and Utah consumers, you have the right to restrict the use and disclosure of sensitive personal information to certain purposes related to the offering of goods or services as listed in the CPRA or UCPA. For Colorado, Connecticut, Virginia, Montana, Texas, and Oregon consumers, we will not process your Sensitive Personal Information without your opt-in consent, and you have the right to revoke such consent at any time. -
Right to Opt Out of Sharing or Selling Personal Information or Processing Personal Information for Purposes of Targeted Advertising:
You have the right to direct us to not share or sell your personal information. -
Right to Opt Out of Profiling in Furtherance of a Decision that Produces a Legal or Similarly Significant Effect:
For Colorado, Connecticut, Virginia, Montana, Texas, and Oregon consumers, you have the right to opt out of the processing of your Personal Information for purposes of profiling in furtherance of a decision that produces a legal or similarly significant effect concerning you, such as decisions we make that result in our provision or denial of financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, health care services, or access to necessities like food and water. We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
J. Other Disclosures
California Residents Under Age 18
If you are a resident of California under the age of 18 and a registered user of our Service, you may request us to remove content or data that you have posted to the Service contacting us at (754) 274-6949. Please note that your request does not ensure complete or comprehensive removal of the content or data, as some of your content or data may have been reposted by another user.
Disclosure About Direct Marketing for California Residents
California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of Personal Information to other entities for their direct marketing purposes in the preceding calendar year. We do not distribute your Personal Information to other entities for their own direct marketing purposes.
Financial Incentives for California Consumers
We offer various types of financial incentives in exchange for your personal information, such as coupons, discounts, promotions, loyalty points, sweepstakes, contests, surveys, and other exclusive offers for California consumers who sign up to receive our marketing emails or join our loyalty program. The amount and terms of such offers will be presented to you at the time of the offer. When you participate in a financial incentive, we collect personal information from you, such as identifiers (like your email address) and commercial information (like your purchase history). Solely for purposes of California privacy law, we reasonably estimate the value of the discount, coupon, or other financial incentive that we offer to you to be equal to or greater than the value we receive from a consumer’s Personal Information collected in connection with the offer. We reasonably estimate the value of a consumer’s data by estimating the expenses related to the provision of each incentive program per consumer. We incur a variety of expenses for providing financial incentives, such as administrative and technical expenses associated with maintaining a loyalty program and costs associated with discounts on purchases. Participation in our financial incentives is voluntary. You may opt into a financial incentive by following the sign-up or participation instructions provided, and you have the ability to opt out by unsubscribing from our emails or closing your loyalty member account.
Changes to our Supplemental Notice
We reserve the right to amend this Supplemental Notice at our discretion and at any time. When we make material changes to this Supplemental Notice, we will notify you by email or posting a pop-up banner on the Service and posting an updated Supplemental Notice on our Service, listing the effective date of such updates.
PRIVACY NOTICE FOR NEVADA RESIDENTS
Effective: July 21, 2024
This Privacy Notice for Nevada Residents adds to the information contained in the Vivunt US Privacy Policy and applies only to Nevada residents (“you,” “your,” or “consumer”).
Personal Information Collection and Purposes of Use
We collect certain personal information of Nevada consumers through our Service. This information includes one or more of the following elements of personally identifiable information:
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A first and last name.
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A home or other physical address that includes the name of a street and the name of a city or town.
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An electronic mail address.
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A telephone number.
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A Social Security Number.
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An identifier that allows you to be contacted either physically or online.
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Any other information concerning you collected from you through the Service and maintained by us in combination with an identifier in a form that makes the information personally identifiable.
We collect this personal information for the following purposes:
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To respond to your inquiries and fulfill your requests;
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To send you important information regarding our relationship with you or regarding this Service, changes to our terms, conditions, and policies, and/or other administrative information;
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For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
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For fraud or crime prevention, and for technical security monitoring purposes;
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To facilitate the development of new products and services;
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To enhance, improve, or modify our Service or products and services;
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For data analysis that will allow us to understand website usage trends;
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To determine the effectiveness of our promotional campaigns so that we can adapt our campaigns to the needs and interests of our users;
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To better understand you so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
Your Privacy Rights
Right to Access and/or Correct Your Personal Information, or Opt-Out of Sale of Personal Information
If you would like to review, correct, or update your personal information, you or your authorized representative may submit your request.
Under Nevada law, you also have the right to direct us not to sell your personal information to third parties.
We will respond to your verified request(s) as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided with a new response date.
CONSUMER HEALTH DATA PRIVACY NOTICE ("CHD Privacy Notice")
Effective Date: February 21, 2024
This Consumer Health Data Privacy Notice supplements the Vivunt US Privacy Policy and State Supplemental Privacy Notice and applies specifically to “Consumers” as defined under applicable U.S. privacy laws regarding Consumer Health Data (collectively, the “CHD Privacy Laws”).
This CHD Privacy Notice describes Vivunt Pharma LLC.’s and each of its affiliates’, subsidiaries’, assigns’, successors’, and brands’ (“Vivunt”, “we”, “us”, or “our”) practices regarding the collection, use, sharing, and disclosure of Consumer Health Data. Any capitalized terms not defined in this CHD Privacy Notice shall have the meanings given to them in the Vivunt US Privacy Policy and the State Supplemental Privacy Notice. This CHD Privacy Notice does not supersede, replace, or otherwise amend the Vivunt US Privacy Policy or the State Supplemental Privacy Notice.
Consumer Health Data Collected
For purposes of this CHD Privacy Notice, Consumer Health Data (“CHD”) is defined under applicable CHD Privacy Laws and includes personal information that is linked or reasonably linkable to a Consumer and that identifies the Consumer’s past, present, or future physical or mental health status.
We do not “sell” Consumer Health Data for monetary consideration. However, we do use cookies for targeted advertising purposes. The collection of data through certain cookies for our targeting advertising purposes may be considered a “sale” under CHD Privacy Laws. If you have consented, we may “sell” Consumer Health Data for the following purposes:
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To operate, manage, and maintain our business;
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To respond to your inquiries and fulfill your requests;
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To conduct audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
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To prevent fraud or crime, and for risk and technical security monitoring purposes;
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To facilitate the development of new products and services;
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To enhance, improve, or modify our Service or products and services;
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To perform research, analytics, and data analysis;
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To determine the effectiveness of our promotional campaigns so that we can adapt our campaigns to the needs and interests of our users;
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To personalize, advertise, and market our products and services;
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To comply with law, legal process, and internal policies;
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To maintain records;
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To exercise and defend legal claims;
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To ensure security and integrity to the extent the use of the Consumer Health Data is reasonably necessary and proportionate for these purposes;
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To perform accounting, audit, and other internal functions, such as internal investigations; and
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Otherwise accomplish our business purposes and objectives.
Your Privacy Rights
Right to Access and/or Correct Your Personal Information, or Opt-Out of Sale of Personal Information
If you would like to review, correct, or update your personal information, you or your authorized representative may submit your request.
Under Nevada law, you also have the right to direct us not to sell your personal information to third parties. While we do not sell your personal information as defined by Nevada law, if you wish to exercise this right, you or your authorized representative may submit a request.
We will respond to your verified request(s) as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided with a new response date.
CONSUMER HEALTH DATA PRIVACY NOTICE ("CHD Privacy Notice")
Effective Date: July 21, 2024
This Consumer Health Data Privacy Notice supplements the Vivunt US Privacy Policy and State Supplemental Privacy Notice and applies specifically to “Consumers” as defined under applicable U.S. privacy laws regarding Consumer Health Data (collectively, the “CHD Privacy Laws”).
This CHD Privacy Notice describes Vivunt Pharma LLC.’s and each of its affiliates’, subsidiaries’, assigns’, successors’, and brands’ (“Vivunt”, “we”, “us”, or “our”) practices regarding the collection, use, sharing, and disclosure of Consumer Health Data. Any capitalized terms not defined in this CHD Privacy Notice shall have the meanings given to them in the Vivunt US Privacy Policy and the State Supplemental Privacy Notice. This CHD Privacy Notice does not supersede, replace, or otherwise amend the Vivunt US Privacy Policy or the State Supplemental Privacy Notice.
Consumer Health Data Collected
For purposes of this CHD Privacy Notice, Consumer Health Data (“CHD”) is defined under applicable CHD Privacy Laws and includes personal information that is linked or reasonably linkable to a Consumer and that identifies the Consumer’s past, present, or future physical or mental health status.
We do not “sell” Consumer Health Data for monetary consideration. However, we do use cookies for targeted advertising purposes. The collection of data through certain cookies for our targeting advertising purposes may be considered a “sale” under CHD Privacy Laws. If you have consented, we may “sell” Consumer Health Data for the following purposes:
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To operate, manage, and maintain our business;
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To respond to your inquiries and fulfill your requests;
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To conduct audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
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To prevent fraud or crime, and for risk and technical security monitoring purposes;
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To facilitate the development of new products and services;
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To enhance, improve, or modify our Service or products and services;
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To perform research, analytics, and data analysis;
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To determine the effectiveness of our promotional campaigns so that we can adapt our campaigns to the needs and interests of our users;
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To personalize, advertise, and market our products and services;
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To comply with law, legal process, and internal policies;
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To maintain records;
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To exercise and defend legal claims;
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To ensure security and integrity to the extent the use of the Consumer Health Data is reasonably necessary and proportionate for these purposes;
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To perform accounting, audit, and other internal functions, such as internal investigations; and
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Otherwise accomplish our business purposes and objectives.
Why the Consumer Health Data is Collected & How it is Used
We, and our Vendors, collect, process, and use the Consumer Health Data described in this CHD Privacy Notice for the following purposes:
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Performing the services or providing the goods reasonably expected by an average consumer who requests those goods or services;
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Ensuring security and integrity to the extent the use of the consumer’s Personal Information is reasonably necessary and proportionate for these purposes;
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Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf;
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Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us;
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Personalizing, advertising, and marketing our products and services;
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Conducting research, analytics, and data analysis;
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Performing accounting, audit, and other internal functions, such as internal investigations;
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Complying with law, legal process, and internal policies;
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Maintaining records;
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Exercising and defending legal claims; and
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Otherwise accomplishing our business purposes and objectives.
Sources of CHD
Why the Consumer Health Data is Collected & How it is Used
We, and our Vendors, collect, process, and use the Consumer Health Data described in this CHD Privacy Notice for the following purposes:
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Performing the services or providing the goods reasonably expected by an average consumer who requests those goods or services;
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Ensuring security and integrity to the extent the use of the consumer’s Personal Information is reasonably necessary and proportionate for these purposes;
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Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf;
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Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us;
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Personalizing, advertising, and marketing our products and services;
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Conducting research, analytics, and data analysis;
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Performing accounting, audit, and other internal functions, such as internal investigations;
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Complying with law, legal process, and internal policies;
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Maintaining records;
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Exercising and defending legal claims; and
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Otherwise accomplishing our business purposes and objectives.
Sources of CHD
We collect Consumer Health Data directly from consumers, as well as from our affiliates, business partners, joint marketing partners, public databases, providers of demographic data, publications, professional organizations, social media platforms, caregivers, third party information providers, affiliates with whom you have a business relationship, Vendors with which we have a contractual relationship and to which you have provided your personal information, cookies and other tracking technologies, and Third Parties when they share the information with us.
Retention Period
We retain your CHD for the period reasonably necessary to provide goods and services to you and for the period reasonably necessary to support our business operational purposes, including but not limited to complying with our legal obligations and for our legal positions (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
Our Sharing of CHD
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Affiliates: We may disclose your CHD to our affiliates for the purposes described in this Privacy Policy.
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Vendors: We may disclose CHD to our Vendors in order to enable them to provide us with products and services, such as web hosting and moderating, mobile application hosting, data analytics, market research, consumer insight, payment processing, order fulfillment, customer service, infrastructure provision, IT services, email and direct mail delivery services, auditing, legal services, and other similar services.
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Third Parties: We may disclose your CHD to the following categories of Third Parties:
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At Your Direction: We may disclose your CHD to any Third Party with your consent or at your direction.
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Other Users and Individuals: If you use our services to interact with other users of the service or other recipients of communications, we will share data, including CHD, as directed by you and your interactions.
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Business Transfers or Assignments: We may disclose your CHD to other entities as reasonably necessary to facilitate a reorganization, merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
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Third Party Co-Branding and Co-Marketing Partners: We may share your CHD with our third-party partners with whom we offer a co-branded or co-marketed promotion.
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Third Party Advertising Partners: To improve the effectiveness of our communication with you and our marketing campaigns, we may share your CHD with our third-party advertising partners, including data analytics providers, market researchers, consumer insight platforms, social media platforms, medical journals, publishers and other similar vendors.
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Legal and Regulatory: We may disclose your CHD to government authorities, including regulatory agencies and courts, as reasonably necessary for our business operational purposes, to assert and defend legal claims, and otherwise as permitted or required by law.
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Exercising Consumer Data Rights
Consumers have certain rights under applicable CHD Privacy Laws with respect to the collection and use of their CHD. These rights may include the right to confirm whether we collect, share or sell your CHD, the right to access such CHD, the right to a list of all third parties and affiliates with whom we have shared or sold the CHD, the right to withdraw consent from our collection and sharing of CHD, and the right to delete your CHD.
You may exercise the consumer data rights applicable to you under the applicable CHD Privacy Laws by clicking [here] or by referring to the “Contacting Us” section in the Vivunt US Privacy Policy.
Changes to this CHD Privacy Notice
We reserve the right to amend this CHD Privacy Notice at our discretion and at any time. When we make material changes to this CHD Privacy Notice, we will notify you by [email or posting a pop-up banner on the Service] and posting an updated CHD Privacy Notice on our Service and listing the effective date of such updates.
Contact
Vivunt Pharma LLC. located at 13350 SW 148th, Suite 110, Miramar, FL 33027, is the company responsible for the collection, use, sharing, and selling of Consumer Health Data under this CHD Privacy Notice.
For questions about this CHD Privacy Notice, please contact us by referring to the “Contacting Us” section in the Vivunt US Privacy Policy.