ScriptSave® Personalized Wellness Program  

Privacy Policy 

 

Effective Date/Last Updated:  December 28, 2020

 

The ScriptSave® Personalized Wellness Program is made available to you by Medical Security Card Company, LLC, a Delaware limited liability company ("MSC", "we", "us", and "our"). This Privacy Policy (“Policy”) describes our policies on the collection, use, and disclosure of personal information about you in connection with your use of the ScriptSave® Personalized Wellness Program, (the “Wellness Program”) which may occur via our mobile application ("Application"). Please note that while we provide the Wellness Program, Website, and Application in conjunction with your third-party sponsoring organization, this Policy reflects the privacy practices of MSC, not your sponsoring organization.  We are not responsible for the privacy practices of third-party sponsoring organizations. Accordingly, when you use the Website, Application or any component of the Wellness Program, you consent to MSC’s collection, use, and disclosure of information about you as described in this Policy. If you do not consent to the collection, use and disclosure of your information as set forth below, you may not access or use the Website, Application, or Wellness Program. Any capitalized term not defined in this Policy has the meaning given in the Terms of Service. 

 

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

 

IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE SECTION 10 BELOW FOR ADDITIONAL PROVISIONS THAT MAY APPLY TO YOU.

 

1.              Information We Collect and Your Choices on How We Use It 

You may download the Application, visit the Website, and use certain features of the Wellness Program without providing us any personal information, although we will collect certain information regarding your visit as set forth below. In order to access and use certain features of the Wellness Program that will allow us to provide you with personalized recommendations for improving your health and wellness, we require you to provide us with certain information to create a user account (“Account”) and with certain health and wellness-related information.

 

Account Information. If you register to create an Account, we require you to provide your first and last name, date of birth, email address, a password, and your zip code.   You may also provide your phone number and gender which will help MSC to provide services more efficiently but this information is not necessary for you to create an Account. We will use your Account to communicate with you and you can access information associated with your Account and the communications settings for your Account within the Settings and User Profile pages of the Website or Application, or by emailing customercare@scriptsave.com.  You cannot opt out of receiving communications from MSC that are administrative or legal notices related to your Account, the Website, the Application, or the Wellness Program. 

 

Health and Wellness Information and Preferences.  In order to use certain features of the Wellness Program, you will need to provide information related to your health concerns, related health information, and dietary preferences.  The Wellness Program provides personalized reminders, recommendations, and guidance regarding allergies, diet and nutrition, fitness, and your medications, in addition to conditions such as heart disease, diabetes, pregnancy, women’s health, men’s health, and general health.  Therefore, we require you to provide certain information depending on what specific goals and/or health concerns you have.

 

User Activity.  We (or our third-party vendors on our behalf) may collect information about your use of the Wellness Program, the Website, and the Application, including but not limited to information about your user activity, the pages you view, and the date, time and duration of your activity.  

 

Internet Activity. We also may collect and store information that your computer or mobile device provides to us in connection with your use of the Wellness Program, Website, and Application, such as your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, unique device identifier (e.g. Google Advertising ID (GAID), Android ID, ID for Advertisers (IDFA), ID for Vendors (IDFV), MAC address, International Mobile Equipment Identity (IMEI), or other device IDs), location, requested and referring URLs, and other information about your device(s), operating system, and the state  from which you accessed the services. We use this information for marketing purposes, to understand how you interact with the Website or Application, and business activities to enhance user experience and increase the usefulness of the Wellness Program, the Application, and Website. 

 

Location Information. In order to enhance your user experience and increase the usefulness of the Wellness Program, the Application, and Website, with your consent, we may access your location.  Provided you have provided your consent, MSC will only access your location while you are using the Application or the Website. You may choose to allow MSC to access your location by granting the Application or the Website, as applicable, access to your device’s location when prompted or through your devices location services settings. 

 

MSC uses the Google Places API(s) for location searches and as a result is using the Google Maps/Google Earth API(s). Pursuant to the Google Maps/Google Earth APIs Terms of Service, use of this location feature is also subject to Google’s privacy policy, which can be found at http://www.google.com/privacy.html.

 

Cookies. Cookies are small data files that consist of unique identifiers and reside on your computer, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of the Wellness Program via the Website or Application such as your browser type, search preferences, and the date and time of your use. Cookies may be persistent or stored only during an individual session and may serve the following purposes:

 

·      To prevent fraud, protect your data from unauthorized parties, and comply with legal requirements. For example, we use cookies to determine if you are logged in to your Account or not. 

 

·      To remember information about how you prefer the Website and Application to behave and look. For example, we use cookies that tell us whether or not you have declined to allow us to use location information. 

 

·      To make the Website, Application, and Wellness Program work in the way you expect it to. For example, we may use a cookie to tell us whether you have already signed up for the Wellness Program and have an Account.

 

·      To help us understand how visitors use the Website and Application. For example, we employ analytics that use cookies to identify which type of device and operating system version you are using to access the Website and Application and how that may affect your user experience.

 

·      To allow notice of information or options that we think could improve your use of the Wellness Program and the Website and Application. For example, we may use a cookie to allow us to stop showing you the sign-up screen if you have already signed in. 

 

·      To gain information about your online activities in order to provide you online ads and other marketing materials as set forth below.  

 

Managing Cookies. It may be possible to disable some (but not all) cookies through your device or browser settings, but doing so may affect your ability to use the Website, Application, and the Wellness Program and your preference settings may not be saved. The method for disabling cookies may vary by device and browser, but can usually be found in the Preferences or Security settings. 

 

Ad Networks. We use third-party ad networks (called third-party ad servers or network advertisers, including but not limited to Google) to deliver ads to you on our behalf. These third party ad networks may place their cookies, web beacons or other technology on the Website or the Application or in your browser to collect information about you when you visit this Website or use the Application (such as browser type, time and date, browsing or transaction activity, subject of advertisements clicked or scrolled over, or a platform-provided identifier during your visits to this and other websites) to enable those third party ad networks to deliver to you advertisements on third party websites and mobile applications for our products or services or those of third parties that are likely to be of greater interest to you. For example, Google uses the DoubleClick cookie to enable it and its partners to serve ads to you based on your visit to our Website and/or other sites on the Internet. 

 

We encourage you to view the privacy policy of advertisers and ad services to learn more about their cookies and other technologies. To learn more about interest-based advertising, or to opt-out, you can visithttp://www.networkadvertising.org/

 

If you do not want to receive those kinds of advertisements, look for the "Ad Choices" icon in the advertisements, which will contain a link to the privacy policy of the ad network that will provide you with information on how to opt-out of receiving such targeted advertising. 

 

You can also visit the website http://www.aboutads.info to change your consumer preferences with respect to certain online ads and to obtain further information about third party ad networks and online behavioral advertising. 

 

Website Analytics.The Website uses Google Analytics to collect information about your use of our Website. This information consists of information that your web browser automatically sends to Google, such as the web address of the page that you visit and your IP address. Google may also set cookies or read preexisting cookies. This information is stored on Google´s servers. Google uses this information to provide us with reports about traffic to our Website and your visit to our Website (such as the domain from which you access the internet, the web address of the website from which you linked to our site, the time and date of your visit to the web pages that you view and click through). We will use this data to improve our Website structure and content. 

 

Google may also use this data in accordance with their privacy policy, which can be found at http://www.google.com/policies/privacy/. For more detailed information on how Google uses your data through our Website, please visit http://www.google.com/policies/privacy/partners/. 

 

You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page and installing the Google Analytics browser add-on, currently made available by Google at https://tools.google.com/dlpage/gaoptout

 

Google Analytics Advertising Features. We have also enabled the following Google Analytics Advertising Features: Google Display Network Impression Reporting, Remarketing with Google Analytics and Google Analytics Demographics and Interest ReportingThe Google Display Network Impression Reporting uses the Google Analytics cookie to track our ad impressions and your interactions with those impressions, including the effectiveness of those ads, which generates reports for us to help us analyze our advertisements. Remarketing with Google Analytics uses the Google Analytics cookie to serve advertisements to you across the Internet based on your visit to our Website. Google Analytics Demographics and Interest Reporting uses a third party cookie to collect information about our website traffic by tracking users across websites and across time, which generates a report for us to better understand our Website users. 

 

We also use the Google AdWords service to serve ads on our behalf across the Internet and sometimes on our Website. Google uses cookies (or other similar identifiers) to collect anonymous information about your visits to our Website and your interaction with our products and services to generate targeted advertisements to you on other sites that you visit across the Internet. 

 

If you do not want Google to collect and use this information you may visit the Google Ad Settings page (http://www.google.com/safetycenter/tools/#manage-your-ads-preferences) or you can also visit the website http://www.networkadvertising.org/choices as referenced above to change your consumer preferences with respect to certain online ads and to obtain further information about third party ad networks and online behavioral advertising. For the Google Analytics Advertising Features, you may also opt-out of our use of Google Analytics as described above. Please remember that changing your settings with certain browsers and ad networks will not carry your privacy choices across browsers and other ad networks. 

 

Audience Measurement.We use third party tools for audience measurement on the Website and Application. Such third party tools may collect anonymous information about our users to help us measure the usage of our Application and Website to better understand our users.  

 

Online Health Initiative Survey. We may collect survey information from our users from time to time. We may use all of the survey information that we collect for our internal business purposes. We may also aggregate and anonymize any survey information and license and distribute or display the same. 

 

In addition to the purposes set forth above, we use the information we collect for the purpose for which it was provided (for example, to fulfill your requests) and to provide the Wellness Program, improve the performance and quality of the Application and Website, personalize your experience, track usage of the Wellness Program, Website, and Application, provide feedback on the Wellness Program, Website, and Application, provide customer support, communicate with you about your Account and use of the Wellness Program, Website, and Application, back up our systems and allow for disaster recovery, enhance the security of the Wellness Program, Website, and Application, and comply with our legal obligations. 

 

2.              Accessing and Correcting Your Information 

You can review and change your personal information by visiting your Account profile page.  You may also send us an email at customercare@wellrx.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. 

 

3.              How We Use Personal Information 

MSC and its suppliers may use and share personal information as described below. We do not use, sell, rent, or otherwise disclose personal information except as stated in this Policy and as permitted by applicable law. 

 

Purpose Collected & Communication With You. We will use and share your personal information and other collected information for the purpose for which it was collected, for example:

 

·      To provide you with personalized recommendations, information, and communications.  For example, if you provide us personal information using our Wellness Program to help you to evaluate your health, wellness or eating habits and food purchases, we will use that information to generate recommendations for you;

·      To process your requests for information and services;

·      To administer MSC business activities;

·      To communicate with you in connection with your Account;

·      To notify you of changes made to the Website or Application (for example, changes to this Policy) or the Wellness Program as a whole; and

·      To provide you with promotional materials and to otherwise market products and services to you. 

 

Evaluation and Improvement of Our Services. We may use personal information to analyze, develop, and improve the content, materials, products, and services that we make available (including the Wellness Program, Website, and Application); to inform marketing and communication plans and strategies; to understand Website and Application demographics and user preferences; and to evaluate Website and Application user needs and customize Website and Application content, promotional emails, and users’ browsing experience. 

 

Aggregate Information. We may also aggregate personal information and other collected information to create aggregate data about the Website and Application’s users that describes users as a group but does not reveal the identity of individual users. We may use aggregate data to understand Website and Application users’ needs, to determine Website and Application user demographics and usage patterns, to determine what kinds of products and services we can provide, and to improve and enrich our products and services, including the Wellness Program, Website, and Application. We may share user information in the aggregate with third-party advertisers and content distributors for our own marketing purposes. For example, we may disclose the number of users that use the Wellness Program, Website, and Application, how they use the Wellness Program, Website, and Application and basic non-personal demographic data. We will not share with third-parties your personal information in a manner that identifies you for any direct marketing purposes by such third-parties nor sell information that could be used to identify you as an individual. 

 

4.              Disclosure of Personal Information

We may share all categories of Personal Information listed above with the following categories of third parties:

 

Employees and Affiliates. We may share personal information with our employees and affiliates who have a need to know the information for our business purposes.

 

Your Third-Party Sponsoring Organization. We may share personal information and aggregate information with your a third-party sponsoring organization, such as your  employer or insurance provider, if you have received access to the Personalized Wellness Program through such a third-party sponsoring organization.

 

Our Service Providers.We contract with a number of service providers and vendors that will have access to your information as necessary to provide the Wellness Program, Website, or Application. These service providers and vendors may include but are not limited to our third-party marketing and ad agencies, our information technology vendors, and our customer service call center vendors. Information shared may include but is not limited to your personal information, the analytics tools discussed above and other analytic tools used to report information to us should we experience technical issues with the Application, Website or the Wellness Program or for various other purposes related to providing the Application, Website or the Wellness Program. Our service providers may also aggregate the information they receive for their own internal analysis and purposes and for inclusion in general databases regarding consumer behavior and trends as described above. You may opt out of individual ad networks as set forth above, if applicable. 

 

Government Officials/Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose personal information: (i) if we believe in good faith we are legally required to disclose that personal information, (ii) if we are advised to disclose personal information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, MSC or any other party.

 

Professional Advisors. We may share personal information with certain service providers that are our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to us.

 

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

 

Change in Ownership. In the event MSC is the subject of a change of control or in the event the Website or Application changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide personal information to the subsequent owner(s).

 

Other. We may share personal information with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the personal information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

 

5.              Data Retention and Account Termination 

You can close your Account by emailing us at customercare@scriptsave.com. We will remove your Account from active status, but we may retain information about you for the purposes authorized under this Policy unless otherwise prohibited by law. 

 

6.              Third-Party Applications

The Application and the Website may link to, or be linked to, websites, applications, features, services, and content not maintained or controlled by MSC (“Third-Party Applications”). Third-Party Applications may include applications maintained by a program sponsoring organization. If you choose to access these Third-Party Applications, you may be requested to log-in and sync your accounts with such applications. You are in no way obligated to use any Third-Party Applications, your access and use of such applications is entirely at your own risk, and we have no associated liability.

 

7.              Children 

The Wellness Program, Website, and Application are not intended for children under 18 years of age. We do not knowingly collect, use, or share Personal Information from children under 18. If a parent or legal guardian learns that their child provided us with personal information without his or her consent, they should contact us and we will make commercially reasonable attempts to delete such personal information.

 

8.              Security 

Your privacy and the security of your personal information is very important to us. We use commercially reasonable technical and organizational measures to help secure personal information against loss, misuse, and alteration appropriate to the type of personal information processed. If a breach of your personal information occurs, we will notify you of the breach if required under applicable law.

 

YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET OR DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.

 

9.              Access from Outside the United States

MSC is based in the United States and the Wellness Program, Website and Application, are hosted in the United States. MSC limits access to the Wellness Program, Website and Application to only those located in the United States; however, if you attempt to gain access from outside the United States and provide your information to MSC, you hereby consent to the transfer of your information to the United States for processing, storage and maintenance in accordance with this Policy and our Terms of Service. Certain governmental authorities may not consider the level of protection of personal information in the United States to be equivalent to that required in other jurisdictions.

 

10.           California Residents

THIS SECTION PROVIDES ADDITIONAL PROVISIONS THAT APPLY ONLY TO RESIDENTS OF CALIFORNIA. In the event of a conflict between this section and the remainder of this Policy, this Section shall take precedence for those California residents.  Certain capitalized terms not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018 as clarified by the State of California’s implementing regulations (the "CCPA").

 

Categories of Personal Information We Collect. We may collect the following categories of Personal Information, which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("Personal Information"):

 

·      Identifiers: Identifiers such as: a real first name, middle initial, last name, name extension (e.g., Jr. Sr., I, II, etc.), date of birth, gender, email address, zip code, postal address (including street address, city, and state), phone number, group number, cardholder ID, member number, relationship code, store number, individual prescription number, password, relationship to insured, NPI (e.g., alias, unique personal identifier, online identifier, internet protocol address ("IP Address"), account name, or other similar identifiers.

 

·      Customer Records: Any of the following types of information: telephone number, medical information, including prescription and medication information.

 

·      Protected Classifications: Characteristics of protected classifications under California or federal law such as: sex, age, and medical conditions.

 

·      Commercial Information: Commercial information, including records of products or services, including prescriptions, purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

 

·      Internet Activity: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.

 

·      Geolocation Data.

 

·      Inferences: Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

Categories of Sources.  We collect your Personal Information from the following sources:

 

·      Directly From You.  We collect Personal Information that you provide directly to us, such as when you contact us, register an Account, and through our health and wellness surveys.

 

·      Automatically.  We automatically collect certain Personal Information from you when you access and use the Website and Application. For example, we may collect information such as the websites you visit before or after you visit the Website or Application, pages you click-on on the Website or Application, IP address, location information, search requests, browser type, browser language, mobile carrier, operating system, data and time you visit the Website or Application, the amount of time spent on the Website or Application, unique device identifier (e.g., Google Advertising ID (GAID), Android ID, ID for Advertisers (IDFA), ID for Vendors (IDFV), MAC address, International Mobile Equipment Identity (IMEI), or other device IDs), requesting and referring URLs, and the device you use to access the Website or Application.

 

Purposes for Collecting Personal Information.  To understand the purposes for collecting your Personal Information, please see Section 3 of this Policy (How We Use Personal Information).

 

Categories of Personal Information Sold.  In the last 12 months, we Sold the following categories of Personal Information, where “Sold” has the definition set forth in the CCPA. See above for more detail on the type of Personal Information in each category.

 

·      Identifiers

·      Customer Records

·      Protected Classifications

·      Commercial Information

·      Inferences

 

Categories of Personal Information Disclosed for a Business Purpose.  In the last 12 months we disclosed the following categories of Personal Information for our own, or one of our service provider’s operational purposes. See above detail on the type of Personal Information in each category.

 

·      Identifiers

·      Customer Records

·      Protected Classifications

·      Commercial Information

·      Internet Activity

·      Geolocation Data

·      Inferences

 

Your Rights to Access and Deletion. Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, you may exercise the following rights with regard to your Personal Information:

 

Right to Access. You have a right to access any of the following which occurred in the prior 12-month period: (a) the categories of Personal Information we collected from you, (b) the categories of sources from which the Personal Information was collected, (c) the business or commercial purpose for collecting or selling your Personal Information, (d) the categories of third parties with whom we shared your Personal Information, (e) the specific pieces of Personal Information we collected from you, and (f) a list of categories of Personal Information we Sold or disclosed for a Business Purpose in the last 12 months.

 

Right to Deletion. You have a right to request that we delete Personal Information we collected from you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.

 

How to Exercise Your Rights. To exercise your rights described in this Policy, you may submit your request to us by contacting us at any of the following:

 

Via Toll-Free Phone at: 1-800-407-8156

 

Via Email at: customercare@scriptsave.com

 

Via Mail at:

Medical Security Card Company, LLC

350 S Williams Blvd

Tucson, AZ 85711

Attention: Compliance Department

 

Who May Exercise Your Rights. You may only make a request to exercise your rights under the CCPA on behalf of yourself. A parent or legal guardian may make a request on behalf of their child. If you are a California resident, only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a request related to your Personal Information. See the section below entitled "Authorized Agents" for more information.

 

Verifiable Consumer Request. In order to verify your request, you must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information and you must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

When We Will Respond. We will try to respond to your request within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your Personal Information to you. We may charge a fee to process or respond to your request if it is excessive or repetitive.

 

Your Rights to Opt-Out of Sales of Personal Information. You may direct us not to sell your Personal Information at any time (this is your right to "opt-out"). You may submit your opt-out request by following this link: [DO NOT SELL MY PERSONAL INFORMATION]

 

You may also opt-out by calling us at: 1-800-407-8156.

 

If you are using an authorized agent to exercise your rights to opt-out of the sale of Personal Information, please see the section below entitled "Authorized Agents" below for the proof required when you use an authorized agent.

 

Non-Discrimination. You have a right to not receive discriminatory treatment for exercising any of your rights under the CCPA. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this section.

 

Authorized Agents. You may designate an authorized agent to make a request on your behalf to exercise your rights under the CCPA. An authorized agent must be registered with the Secretary of State in California to conduct business in California. If you choose to use an authorized agent, you must: (1) provide the authorized agent signed permission to do so; (2) verify your own identity with us; and (3) directly confirm with us that you provided the authorized agent permission to submit the request.

 

CALIFORNIA’S "DO-NOT-TRACK" REQUIREMENT. WE CURRENTLY DO NOT HONOR "DO NOT TRACK" REQUESTS.

 

Alternative Format of this Policy.  This Policy is accessible to consumers with disabilities. If you are unable to access this policy in a form or format that allows you to read it, you may contact us using the contact information below.

 

Shine the Light.  Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by contacting us per the Contacting Us section below.

 

Contacting Us 

 

If you have any other questions or concerns regarding this Policy, please contact us as follows: 

 

Via email at: 

 

Or by Mail at: 

 

Medical Security Card Company, LLC 
4911 E. Broadway Blvd. 

Tucson, AZ 85711 

 
Or by Phone at: 1-800-407-8156