Updated and Effective as of: December 2023

Prescryptive Health Inc (“Prescryptive”, “we”, or “us”) is committed to protecting your privacy. This Privacy Policy (“Privacy Policy”) describes how we process Personal Information (as defined below) that’s collected when you interact with Prescryptive websites (the “Sites”) or when using any Prescryptive products, services or offerings (the “Services”). This Privacy Policy is only applicable to Prescryptive’s Sites and Services, and not to any other third-party websites or services that you may be able to access from the Site or Services, each of which may have privacy practices and policies that differ materially from those contained in this Privacy Policy.

It is important that you carefully review this Privacy Policy before accessing our Sites and Services. To the extent permitted by applicable law, by providing your Personal Information (as defined below) to us or otherwise interacting with us, you are agreeing to this Privacy Policy.

1. Information We Collect

This section describes information we collect or receive about you during your interactions with our Sites and Services. In this Privacy Policy, we use the term “Personal Information” to refer to any information that can reasonably be used to directly or indirectly identify you. Examples include your name, address, telephone number, e-mail address, characteristics, or descriptions (such as gender and date of birth), and other similar and associated information.

Information you provide through our Sites and Services

In some cases, we collect Personal Information directly from you. We will ask you for Personal Information when you interact with us, such as registering on our Sites, using any interactive features or applications, signing up to receive product information, or choosing to share your experiences with us. For example, a person seeking employment may choose to apply for a job online or request additional information about job opportunities; a health care professional might ask that we send information about one or more of our products.

Information we collect through third-party sources

We may obtain information about you through third-party sources, including but not limited to, requests for reimbursement, eligibility files or claims data that we receive from your employer or health benefit plan, pharmacies and prescribers who contact us regarding your health plan benefits, medication history or other information from family members and personal representatives who are registered with or interact with Prescryptive on your behalf.

If you are interacting with our Sites as a potential business customer of Prescryptive, we may supplement your Personal Information (e.g., information you enter through our “Contact Us” page) with information we receive from marketing partners and social media companies. We may combine this information with the information we collect about you to help us tailor our communications and improve our Services.

We also collect information from our vendors, suppliers, consultants, professional advisors, and other third parties for the purposes of managing and operating our business. For example, we will collect business contact information, financial information, and other information necessary to engage our suppliers and other business partners and to evaluate their performance.

Information we collect automatically through our Sites

Through your use of our Sites, we collect related information by automated means, such as the date and time of your website sessions, movement across our Sites, and the browser information and operating system you use and other system settings, as well as the language your system uses and the country, region, and time zone where your device is located (collectively, “Usage Data”). Usage Data also includes the IP Address of the device you use to connect to the internet that is collected by our website server logs. An IP address is a unique identifier that devices use to identify and communicate with each other on the internet. In certain circumstances where we link Usage Data and Personal Information, Usage Data may be considered Personal Information.

Digital Advertising, Cookies and Other Data Collection Technologies

When you use our Sites, we collect different types of Usage Data by automated means, using technologies such as Application Programming Interfaces, web services, scripts, cookies, pixels, tags, web beacons, browser analysis tools, and server logs. Using these technologies enables certain services we use including advertising, visitor tracking, personalization, website analytics and security services. We may also use vendors, such as Adobe and Google, to provide these services, and the data may be disclosed to our vendors for these purposes.

We use cookies from third-party advertising companies that may place an advertising tag on your web browser. The advertising tag allows third parties to serve our ads to you on other websites and digital services. These companies may use information obtained from cookies and other data collection tools to measure advertising effectiveness and provide advertisements of interest to you on these other websites.

Other data may be disclosed to vendors providing additional services integrated into our Sites, including performance monitoring, user experience components such as user interface frameworks, images and web fonts, and maps. When we send email communications, we may place a web beacon or similar tracking technology in the email to know whether your device is capable of receiving HTML emails, or to collect data on whether the email or an attachment or link in the email has been opened or forwarded.

2. How We Use Your Information

We may use your Personal Information as outlined below:

• Furnish the Services. We may use your Personal Information to furnish the Services, including interactions with health care providers, plan sponsors, benefits administrators, and pharmacies to verify eligibility for our Services, obtain prior authorization, manage prescriptions, process claims, provide customer service, create and maintain business records, respond to your questions and comments, and send you communications, including notifications and alerts, about the Services.
• Build and maintain our relationship with you. We may use your Personal Information to improve your experience with our Services, send you marketing messages about the Services that may be of interest to you, send you educational materials, and obtain and respond to your feedback, questions, and comments. We may also draw inferences from the Personal Information we receive about you, such as information about your preferences, characteristics, and interest in our Services.
• Improve the Services. We may use your Personal Information to facilitate and improve the operation of the Services, perform market research and analysis, analyze how the Services are being used and accessed, improve the functionality of the Services and your user experience, conduct quality assurance activities, perform internal business reviews, and develop new Services.
• Maintain security of the Services. We may use your Personal Information to maintain the security and integrity of the Services, detect security incidents, protect our Services against fraudulent and illegal activity, and enforce the terms of use applicable to our Sites and Services.
• For research and development purposes. We may deidentify, pseudonymize, or anonymize your Personal Information by removing data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through other means. We do this so that we can conduct research and develop our Services.
• Comply with legal obligations and respond to legal proceedings. We may use your Personal Information to comply with our legal obligations, including maintaining records of our compliance with federal and state law requirements. We may also use your Personal Information to establish, exercise, or defend legal claims.

We may use and share aggregated and deidentified data and information derived from your Personal Information with other entities for the purpose of performing activities that may help us provide and improve our Services. Where we aggregate or deidentify data, we take reasonable steps to ensure the information is not reidentified except as required by or pursuant to applicable law.

We may also use your information for other purposes consistent with the context of the collection of your Personal Information as otherwise disclosed to you at the time your Personal Information is collected, or with your consent.

3. How We Disclose the Information Collected

Service providers. We may disclose your Personal Information with our service providers for the purposes described in Section 1 above, including organizations that provide services related to: maintaining, operating, hosting, and improving the Services; payment processing; customer service; sending emails; technical support; data analytics; and marketing. It is our policy to limit our service providers’ use of your Personal Information to that which is necessary to perform their services for us.

Delivery of Services. We may disclose your Personal Information to providers, pharmacists, pharmacies or your benefit plan to facilitate delivery of the requested Services.

Your employer. If your access to our Services is offered in connection with a program through or supported by your employer, we will share certain Personal Information with your employer including your member identification number, use of applicable services, and satisfaction survey results. In certain circumstances your employer or benefit plan may ask that we share certain Personal Information with a third-party designated provider to use for their own purposes.

In connection with a business transaction. We may disclose your Personal Information in the course of a business or data transaction, business relationship, and in the event of a bankruptcy, merger, acquisition, sale of all or part of our business, or other change of ownership or control (whether in whole or in part).

Required by law. Prescryptive may disclose Usage Data or Personal Information if required by law or if Prescryptive believes that disclosure is necessary to protect or defend the rights or property of Prescryptive, our Sites, or the users of our Sites, or to comply with a judicial proceeding, court order, or other legal process.

No other uses. Except as provided for in this Privacy Policy, we do not share, sell, rent, or trade any information provided with third parties for promotional purposes.

4. Your Privacy Choices

You will be given opportunities to make choices about the data we receive and how we use it.

Tracking technologies and advertising. Your web browser settings allow you to change your cookie settings. Please be aware that website functions may not work well if you choose to reject some cookies.

Promotional communications. You may optout of email marketing at any time by selecting “unsubscribe” at the bottom of the email.  Note that some email communications are required as part of your use of the Services and cannot be unsubscribed.

Targeted advertising. You can optout of receiving targeted advertising by disabling targeting cookies through our cookie preference center.

For additional information on how to optout of receiving targeted advertising, you can also visit www.thenai.org/opt-out and www.youradchoices.com.

5. Data Protection

Consistent with applicable laws and requirements, we have put in place reasonable physical, technical, and administrative safeguards designed to protect Personal Information from loss, misuse, alteration, theft, unauthorized access and unauthorized disclosure consistent with legal obligations and industry practices.

We are not responsible for any interception or interruption of communications, or for changes to or losses of data through the internet. Users of our Sites or Services are responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to password protected or secure areas of our Sites or Services. Any access to our Sites or Services through your user ID and password will be treated as authorized by you. If we believe it is necessary or advisable to help protect your Personal Information and/or the integrity of our Sites or Services, we may suspend your use of all or part of our Services without notice. Unauthorized access to any of our Sites or Services is prohibited and may lead to criminal prosecution.

6. Children’s Privacy

If you are under the age of 13, you may only use our Sites or Services with the supervision and consent of your parent or legal guardian. If we learn we have collected Personal Information from someone under the age of 13 that was not provided with the supervision and consent of the minor’s parents or legal guardian, we will we take steps to remove such information and terminate the child’s account. If you believe we have impermissibly collected personal information from someone under the age of 13, please contact us at privacy@prescryptive.com. Neither our Sites nor our Services are directed to children under 13.

7. Links to Other Websites

Our Sites may contain links or otherwise provide access to another website, mobile application, or internet location (collectively “Third-Party Sites”). Please note that we have no control over and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Policy does not apply to Third-Party Sites. We encourage you to review the privacy policies of any website or application with which you interact.

8. How Long We Retain Your Personal Information

We retain information as long as it is necessary and relevant for our business, operational, and legal purposes. In addition, we retain Personal Information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, and other actions permitted by law.

When your Personal Information is no longer needed for Prescryptive’s business, operational, and legal purposes, we may dispose of it without notice to you. Whenever possible, we aim to de-identify the information or otherwise remove some or all information that may identify you from records that we may need to keep for periods beyond the specified retention period.

9. Nevada Residents

Prescryptive does not sell Covered Information as defined under Nevada law. If you would like to make a further inquiry regarding the selling of your Covered Information as defined under Nevada law, please send an email to privacy@prescryptive.com.

10. California Residents

California residents may request and obtain from us, once a year, free of charge, a list of third parties, if any, to which we disclosed their Personal Information for direct marketing purposes during the preceding calendar year and the categories of Personal Information shared with those third parties. If you are a California resident and wish to obtain that information, please submit your request by sending an email to privacy@prescryptive.com with “California Privacy Rights” in the subject line or by writing to us at: Privacy Office, Prescryptive Health, Inc., PO Box 403, Redmond WA 98073.

11. Additional Notices for Certain Other U.S. Residents

Certain other U.S. residents may be granted the following rights under the laws of your state of residence:

• To access your Personal Information.
• To correct inaccuracies in your Personal Information.
• To delete your Personal Information that we have obtained.
• To receive a copy of your Personal Information in a portable and readily usable format.
• To opt in or opt out of certain types of sensitive Personal Information processing.
• To opt out of the processing of your Personal Information for purposes of (i) targeted advertising or (ii) automated decision-making or profiling in furtherance of decisions that produce a legal or similarly significant effect on you.

If you choose to exercise any of these rights, please do so by submitting a written request to privacy@prescryptive.com. Prescryptive will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our Sites or Services. You may have the right to appeal our decision if we deny your rights request. To submit an appeal, contact us at privacy@prescryptive.com.

12. How to Contact Us

If you have any questions about Prescryptive’s Privacy Policy, would like to exercise one of your rights, or would like to submit a concern or complaint, please contact us at privacy@prescryptive.com. You can also write to us at: Privacy Office, Prescryptive Health, Inc., PO Box 403, Redmond WA 98073.

13. Updates to This Policy

We may update this Privacy Policy from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the top of this Privacy Policy. We encourage you to review this Privacy Policy often to stay informed of how we may process your information.