Effective Date: August 31, 2021
Last Updated: August 31, 2021
data collection by EasyRx and shall apply to your use of the website, www.easyrxcloud.com,
EasyRx-branded apps, and other EasyRx-related sites, apps, communications, capabilities and
services (“Services”) accessible on or by any top-level EasyRx domain owned by us (each, a “Site”
and collectively the “Sites”), but excluding services that state that they are offered under a different
you (“User” or “you”) on the Sites.
and share that information; (3) the choices we offer, including how to access and update information.
2. Terms of Service
3. Information We Collect
4. How We Use Information We Collect
5. Our Legal Basis for Collecting Personal Data
6. Information We Share
7. Your Failure to Provide Personal Data
8. Our Retention of Your Personal Data
9. Your Privacy Choices
10. Privacy Rights Specific to European Union Residents
11. Our Opt-in/Out-out Policy
12. Third Party Links
13. International Data Transfer
14. How We Protect Personal Data
16. Direct Marketing and “Do Not Track” Signals
18. How to Contact Us
Please familiarize yourself with our privacy practices and let us know if you have any questions. By
Policy, please do not use the Sites.
Irrespective of which country you live in, you authorize us to transfer, store, and use your information
in the United States, and any other country where we operate. In some of these countries, the
privacy and data protection laws and rules regarding when government authorities may access data
may vary from those in the country where you live. Learn more about our data transfer operations in
the “International Transfer” section below. If you do not agree to the transfer, storage and use of
your information in the United States, and any other country where we operate, please do not use
the Sites or Services.
offered on other sites, but excludes services that have separate privacy policies that do not
products or sites that may be displayed to you, or other sites linked from our services. Our Privacy
Policy does not cover the information practices of other companies and organizations who advertise
Terms of Service
By accessing or using the Sites in any manner, you also agree to be bound by our Terms of Service
(the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and
conditions contained in or incorporated by reference into the Agreement, please do not use the
Information We Collect
We collect information, including personal data, to provide better services to all our Users. We use
the term “Personal Data” to refer to any information that identifies or can be used to identify you.
Common examples of personal data include: full name, home address, email address, digital
identity, such as a login name or handle, information about your device, and certain metadata.
We collect Personal Data in the following ways:
1. Information You Give to Us
You may choose to provide us with Personal Data about yourself, including your name,
organization, phone number and email address, by completing forms on our website,
such as when you request information about our Services. In some instances, you may
elect to provide us with location and address information. You may also provide us with
Personal Data about yourself when your report a problem or have a question.
Please note that if you do not provide us with Personal Data, your ability to use certain
aspects of our services may be limited.
2. Information We Obtain from Your Use of Our Services
We collect certain information automatically, such as your operating system version,
browser type, and internet service provider. When you use our Site, we automatically
collect and store this information in service logs. This includes: details of how you used
our Site; Internet protocol address; and cookies that uniquely identify your browser. We
may also collect and process information about your actual location. The information we
collect automatically is statistical data and may or may not include Personal Data, but
we may maintain it or associate it with Personal Data we collect in other ways or
receive from third parties.
3. Health and Other Special Categories of Personal Data
Under a federal law called the Health Insurance Portability and Accountability Act
(“HIPAA”), some demographic, health and/or health-related information that EasyRx
collects as part of providing the Services may be considered “protected health
information” or “PHI”. HIPAA provides specific protections for the privacy and security
of PHI and restricts how PHI is used and disclosed. EasyRx handles all PHI in strict
accordance with applicable laws and regulations. In addition, EasyRx Partners shall be
All Protected Health Information that EasyRx processes is used and disclosed by us as
a Business Associate (as defined by HIPAA) according to the terms of a Business
Associate Agreement between us and that healthcare provider. EasyRx Partners, to the
extent they are bound by HIPAA, are also required to describe their privacy practices.
4. Cookies and Similar Technologies
We and our partners use various technologies to collect and store information when you
visit one of our services, and this may include using cookies or similar technologies to
identify your browser or device. We also use these technologies to collect and store
information when you interact with services from our partners, such as advertising
services. Our third party advertising and analytics partners include Google, Facebook,
Twitter, and similar third party advertising or analytics partners.
The technologies we use for this automatic data collection may include:
Cookies. A cookie is a small file placed on the hard drive of your computer. You may
refuse to accept browser cookies by activating the appropriate setting on your browser.
However, if you select this setting you may be unable to access certain parts of our
our system will issue cookies when you direct your browser to our services.
Web Beacons. Pages of our services or our e-mails may contain small electronic files
known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs)
that permit us, for example, to count users who have visited those pages or opened an
e-mail and for other related website statistics (for example, recording the popularity of
certain website content and verifying system and server integrity).
How We Use Information We Collect
We use your personal data in ways that are compatible with the purposes for which it was collected
or authorized by you, including for the following purposes:
1. To inform you about services available from EasyRx;
2. To authorize access to our Sites and Services;
3. To provide you with Services;
4. To administer content, sweepstakes, promotions, surveys or other Site features;
5. To communicate about, and administer your participation in, special programs, surveys,
and other offers or promotions, and to deliver pertinent emails;
6. To improve our customer service;
7. To respond to and support customers regarding their use of the Sites and Services;
8. To comply with all applicable legal requirements.
9. To investigate possible fraud or other violations of our Terms of Service or this Privacy
Policy and/or attempts to harm our Users.
We use the information we collect from our Sites to provide, maintain, and improve them, to develop
new services, and to protect our Company and our customers.
We use information collected from cookies and other technologies, to improve your user experience
and the overall quality of our services. We may use your Personal Data to see which web pages you
visit at our Site, which web site you visited before coming to our Site, and where you go after you
leave our Site. We can then develop statistics that help us understand how our visitors use our Site
and how to improve it. We may also use the information we obtain about you in other ways for which
we provide specific notice at the time of collection.
We will ask for your consent before using information for a purpose other than those set out in this
Our Legal Basis for Collecting Personal Data
Whenever we collect Personal Data from you, we may do so on the following legal bases:
1. Your consent to such collection and use;
2. Out of necessity for the performance of an agreement between us and you, such as
your agreement to use our Services or your request for Services;
3. Our legitimate business interest, including but not limited to the following circumstances
where collecting or using Personal Data is necessary for:
o Intra-organization transfers for EasyRx data for administrative purposes;
o Product development and enhancement, where the processing enables
EasyRx to enhance, modify, personalize, or otherwise improve our
Services and communications for the benefit of our visitors, and to better
understand how people interact with our Sites;
o Fraud detection and prevention;
o Enhancement of our cybersecurity, including improving the security of our
network and information systems; and
o General business operations and diligence;
Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose
against your privacy and confidentiality interests, including taking into account your reasonable
expectations, the impact of processing, and any safeguards which are or could be put in place. In all
circumstances, we will limit such processing for our legitimate business interest to what is necessary
for its purposes.
Information We Share
We do not share Personal Data with companies, organizations and individuals outside of the
Company unless one of the following circumstances applies:
• With your consent. We will share personal data with companies, organizations or
individuals outside of EasyRx when we have your consent to do so.
• For external processing. We provide Personal Data to our affiliates or other trusted
businesses or partners to process it for us, based on our instructions and in compliance
These third parties include analytics and advertising providers, social media sites, and
payment processors. It is our policy to only share Personal Data with contractors,
service providers and other third parties who are bound by contractual obligations to
keep Personal Data confidential and use it only for the purposes for which we disclose it
to them. Under certain circumstances, you may avoid having us share your information
with our business partners and vendors by not granting us permission to share your
information. Not granting us permission to share your information with our business
partners or vendors may limit your access to their services through the Sites.
• For Legal Reasons. We will share Personal Data with companies, organizations or
individuals outside of EasyRx if we have a good-faith belief that access, use,
preservation or disclosure of the information is reasonably necessary to:
o meet any applicable law, regulation, legal process or enforceable
o enforce applicable Terms of Service, including investigation of potential
o detect, prevent, or otherwise address fraud, security or technical issues.
o protect against harm to the rights, property or safety of EasyRx, our Users
or the public as required or permitted by law.
We attempt to notify Users about legal demands for their personal data when appropriate in our
judgment, unless prohibited by law or court order or when the request is an emergency. We may
dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or
lack proper authority, but we do not promise to challenge every demand.
• Business Transfers. As we continue to develop our business, we may buy, sell, or
share assets in connection with, for example, a merger, acquisition, reorganization, sale
of assets, or bankruptcy. In such transactions, Personal Data about our users is often a
transferred business asset. In the event that EasyRx itself or substantially all of our
assets are acquired, Personal Data about our users may be one of the transferred
• Aggregate Site Use Information. We may share aggregate and
anonymized/pseudonymized Personal Data to advertisers and other third parties in
order to promote or describe use of the Sites.
Your Failure to Provide Personal Data
Your provision of Personal Data is required in order to use certain parts of our services and our
products. If you fail to provide such Personal Data, you may not be able to access and use our
services and/or our products, or parts of our services and/or our products.
Our Retention of Your Personal Data
We may retain your Personal Data for a period of time consistent with the original purpose for
collection. For example, we keep your Personal Data for no longer than reasonably necessary for
your use of our products and services and for a reasonable period of time afterward. We also may
retain your Personal Data during the period of time needed for us to pursue our legitimate business
interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our
Your Privacy Choices
You may have certain rights relating to your Personal Data, subject to local data protection law.
Subject to applicable law, you may obtain a copy of Personal Data we maintain about you. In
addition, if you believe that Personal Data we maintain about you is inaccurate, subject to applicable
law, you may have the right to request that we correct or amend the information by contacting us as
indicated in the “How to Contact Us” section below. To help protect your privacy and maintain
security, we will take steps to verify your identity before granting you access to the information.
Privacy Rights Specific to European Union Residents
The European Union’s General Data Protection Regulation (“GDPR”), and corresponding legislation
in the United Kingdom and Switzerland, provide European, Switzerland and United Kingdom
residents with certain rights in connection with Personal Information you have shared with us. If you
are resident in the European Economic Area, you may have the following rights:
• The right to be informed. You are entitled to be informed of the use of your Personal
• The right of access. You have the right to request a copy of your Personal Information
which we hold about you.
• The right of correction. You have the right to request correction or changes of your
Personal Information if it is found to be inaccurate or out of date.
• The right to withdraw consent. You have the right to withdraw a previously given
consent for processing your Personal Information for a specific purpose.
• The right to be forgotten. You have the right to request us, at any time, to delete your
Personal Information from our servers and to erase your Personal Information when it is
no longer necessary for us to retain such data. Note, however, that deletion of your
Personal Information will likely impact your ability to use our services.
• The right to object (opt-out). You have the right to opt-out of certain uses of your
Personal Information, such as direct marketing, at any time.
• The right to data portability. You have the right to a “portable” copy of your Personal
Information that you have submitted to us. Generally, this means your right to request
that we move, copy or transmit your Personal Information stored on our servers or
information technology environment to another service provider’s servers or information
• The right to refuse to be subjected to automated decision making, including profiling.
You have the right not to be subject to a decision and insist on human intervention if the
decision is based on automated processing and produces a legal effect or a similarly
significant effect on you.
• The right to lodge a complaint with a supervisory authority. You have the right to lodge
complaints about our data processing activities by filing a complaint with us or with the
relevant Supervisory Authority. A list of Supervisory Authorities is available
You may exercise any of the rights described in this section by sending an email
to email@example.com. Please note that we may ask you to verify your identity and request
before taking further action on your request. We may respond to your request by letter, email,
telephone or any other suitable method.
Our Opt-in/Opt-out Policy
By providing an email address on the EasyRx Sites, you agree that we may contact you in the event
with information about our events, invitations, or related educational information.
submit or receive information, as the case may be.
We currently provide the following opt-out opportunities:
1. At any time, you can follow a link provided in offers, newsletters or other email
messages (except for e-commerce confirmation or service notice emails) received from
us to unsubscribe from the service.
2. At any time, you can contact us through firstname.lastname@example.org or the address or
telephone number provided below to unsubscribe from the service and opt-out of our
Third Party Links
The Sites may contain links to webpages operated by parties other than EasyRx. We do not control
such websites and are not responsible for their contents or the privacy policies or other practices of
such websites. Our inclusion of links to such websites does not imply any endorsement of the
material on such websites or any association with their operators. Further, it is up to the User to take
precautions to ensure that whatever links the User selects or software the User downloads (whether
from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and
other items of a destructive nature. These websites and services may have their own privacy
policies, which the User will be subject to upon linking to the third party’s website. EasyRx strongly
recommends that each User review the third party’s terms and policies.
International Data Transfer
We may, directly or indirectly through third-party entities around the world, process, store, and
transfer the information you provide, including your Personal Data, as described in this Privacy
Policy. Specifically, the information and Personal Data that we collect may be transferred to, and
stored at, a location outside of your jurisdiction. It may also be processed by staff operating outside
have put in place commercially reasonable technical and organizational procedures to safeguard the
information and Personal Data we collect on the Sites.
We will, subject to applicable law, rely upon legally permitted data transfer mechanisms in order to
transfer, process and store your Personal Data in a jurisdiction outside of your home jurisdiction. We
ensure that the recipient of your Personal Data offers an adequate level of data protection and
How We Protect Personal Data
EasyRx maintains administrative, technical and physical safeguards designed to protect the User’s
Personal Data and information against accidental, unlawful or unauthorized destruction, loss,
alteration, access, disclosure or use. We implement appropriate technical and organizational
measures to ensure a level of security appropriate to the risk, taking into account technological
reality, cost, the scope, context and purposes of processing weighted against the severity and
likelihood that the processing could threaten individual rights and freedoms. For example, we use
commercially reasonable security measures such as encryption, firewalls, and transport layer
security (TLS) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.
The Site is not intended for use by children. We do not intentionally gather Personal Data about
visitors who are under the age of 13. If a child has provided us with Personal Data, a parent or
guardian of that child may contact us to have the information deleted from our records. If you believe
that we might have any information from a child under age 13, please contact us
at email@example.com. If we learn that we have inadvertently collected the Personal Data of a
child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the
information as soon as possible.
Direct Marketing and “do Not Track” Signals
EasyRx does not track its customers over time and across third party websites to provide targeted
advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third
party sites do keep track of your browsing activities when they serve you content, which enables
them to tailor what they present to you. If you are visiting such sites, your browser may include
controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out
of data collection through those technologies.
changes are significant, we will provide a more prominent notice (including, for certain services or
How to Contact Us
to us at the address below:
3150 Arden Road, NW, 3rd Floor,
Atlanta, Georgia 30305