Healthy Web Inc. Privacy Notice for California Residents

Effective Date: January 1, 2020

This Privacy Notice for California Residents supplements the information contained in Healthy Web Inc.’s (“Fullscript”) privacy statement and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We have adopted this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) which came into effect January 1, 2020 and any terms defined in the CCPA have the same meaning when used in this Notice. 

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:

  • Publicly available information from government records;
  • Deidentified or aggregated consumer information; and
  • Information excluded from the CCPA’s scope, such as, health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

 

In particular, as required by the CCPA, the following categories of personal information have been collected from consumers within the last twelve (12) months:

  • identifiers such as your name, alias, address, phone numbers, email address, account name, Social Security Number, or IP address;
  • personal information, such as a signature, education or credit card number;
  • commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Internet or other similar network activity information, such as cookie data, information on a consumer’s interaction with a website, application, or advertisement;
  • geolocation data, such as the approximate location of your device or computer;
  • if you are a student practitioner, education records directly related to you maintained by an educational institution or party acting on its behalf, such as transcripts, or student identification codes;
  • professional information, for example data you may provide about your business or your professional qualifications; and
  • inference data, such as information about your purchase preferences.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you, for example, from forms you complete or products and services you purchase.
  • Indirectly from you, for example, from actions you take on our website or through our services you use.

Use of Personal Information

We may use, sell (as “sell” is defined in the CCPA) if you are a practitioner, or disclose the personal information we collect for one or more of the following purposes: 

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information in the set-up of an account or to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate subsequent product orders or process returns. 
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose or, if you are a practitioner using Fullscript, sell your personal information (as defined in the CCPA), subject to your right to opt-out of those sales. The CCPA prohibits third parties who “purchase” the personal information we provide to them from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We may share your personal information with the following categories of third parties: 

  • Service providers
  • Brand Suppliers
  • Government Entities
  • Partners.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose: 

A: Identifiers, such as name, alias, address, phone numbers, email address; account name, Social Security Number, or IP address;

B: California Customer Records personal information categories;

C: Commercial information, such as products or services purchased;

D: Geolocation data; and

E: Professional information.

We disclose your personal information for a business purpose to the following categories of third parties: 

  • Service providers;
  • Brand suppliers from whom we purchase the products we sell on our website.

Sales of Personal Information 

In the preceding twelve (12) months, if you are a practitioner, the Company may have sold the following categories of personal information: 

  1. Identifiers;
  2. California Customer Records personal information categories;
  3. Commercial information;
  4. Geolocation data; and
  5. Professional-related information.

We may sell your personal information (if you are a practitioner with a Fullscript account) to the following categories of third parties: 

  • Partners;
  • Brand suppliers from whom we purchase the products we sell on our website.

Your Rights and Choices 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and 
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 

Deletion Request Rights 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  3. Debug products to identify and repair errors that impair existing intended functionality;
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
  6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  7. Comply with a legal obligation; and
  8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: 

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include, your first and last name and email address.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

For instructions on exercising sale opt-out rights, see below.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to a total of 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to your contact address on that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”) with “sell” having the meaning given to it in the CCPA. We do not sell the personal information of consumers we actually know are less than 16 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by either 

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by contacting us by either of the contact methods listed above.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request. 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or write us at: Privacy, 245 Cooper Street, Ottawa, ON, Canada, K2P 0G2.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Healthy Web Inc. dba Fullscript collects and uses your information described here and in our Privacy Statement, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-866-807-3828

Email: [email protected]