Privacy Policy

Effective Date: April 29, 2019

 

This website, www.asopfoundation.pharmacy (this “Site”), is owned and operated by the Alliance for Safe Online Pharmacies Foundation (“ASOP Foundation”).

If you have any questions about this Policy or our privacy practices, please contact us at the information listed below.

Scope of This Policy
Your Consent
Types of Information We Collect
How We Use Information Collected Through This Site
Your Choices
How to Access, Update or Correct Your Personal Information
Steps We Take to Safeguard your Personal Information
How We Share Your Information With Others
Children Under the Age of Thirteen
Links to Other Sites
European Data Protection Law
Privacy Rights in Other Jurisdictions
Contact Information
This Policy May Change

Scope of This Policy

This Policy applies only to information collected through this Site. It does not apply to third-party websites or to other websites owned by ASOP. It also does not apply to information collected through other channels, such as over the phone or in person.

Some of the information we collect through this Site may be “personal information”—information that identifies you personally, alone or in combination with other information available to us. Other information may be nonpersonally identifiable, such as information collected by cookies.

 

Please take a few minutes to review this Policy before using this Site. By using this Site, to the extent permitted by applicable law, you are consenting to the collection, use, and disclosure of your information as set forth in this Policy. If you do not agree to be bound by this Policy, you should not access or use this Site.

 

Types of Information We Collect

 

  • Information you manually provide. ASOP collects the information you and others knowingly and voluntarily provide when you use this Site. For example, we collect the information you provide when you subscribe to our email updates, send us a testimonial, contact us with questions, or otherwise interact with this Site. Some of the information you post to this Site may constitute personal information.
  • Information from your browser or device. ASOP collects information that is sent to us automatically by your web browser or mobile device. This information typically includes your IP address, the name of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. The information we receive may depend on your browser or device settings. The information we receive from your web browser and device is not, in and of itself, personally identifiable. However, we may combine it with other information in an attempt to identify you or we may combine it with information that does identify you.
  • Information Collected by Cookies and Other Technologies. A “cookie” is a small file placed on your device when you visit a site that can be understood by the site that issued the cookie. We use cookies and other technologies, including device identifiers, to collect information and support certain features of this Site. For example, we may use these technologies to:
  • collect information about the ways visitors use this Site—which pages they visit, which links they use, and how long they stay on each page;
  • support the features and functionality of this Site—for example, to save you the trouble of reentering information already in our database or to prompt the settings you established on previous visits;
  • personalize your experience when you use this Site; and
  • improve our marketing efforts, including through use of targeted advertising. For more information, please see our Cookies Notice.

 

In addition to the cookies we deliver to your computer or device through our site, certain third parties may deliver cookies to you for a variety of reasons. For example, we may use Google Analytics, a web analytics tool that helps us understand how visitors engage with our site. To learn more about Google Analytics, click here. You have choices about the collection of information by third parties on our Site. For example, if you don’t want information about your visit to this Site sent to Google Analytics, you may download an Opt-out Browser Add-on by clicking here. Please note that the Add-on does not prevent information from being sent to ASOP.

 

 

How We Use Information Collected Through This Site

Generally, we use the information we collect through this Site

  • to provide the information, products and services you request;
  • for security, credit or fraud prevention purposes;
  • to provide you with effective customer service;
  • to provide you with a personalized experience when you use our Sites;
  • to contact you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
  • to contact you with information and notices related to your use of our Sites;
  • to invite you to participate in surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us);
  • to better understand your needs and interests;
  • to improve the content, functionality and usability of this Site;
  • to improve our products and services;

to improve our marketing and promotional efforts; and

for any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.

Please see below for information about the choices you have about the ways we use your information.

 

Your Choices

 

In General. We respect your right to make choices about the ways we collect, use, and disclose the information you provide on or through this Site. We strive to provide choices to you at a meaningful time and in a meaningful place. This Policy describes some of your other choices, such as your choice to opt out of receiving “cookies.”

Do Not Track Mechanisms. Your browser may deliver a “Do-Not-Track (‘DNT’) signal” to this Site. Because of the changing state of technology and indecision within the technology and marketing industries regarding the meaning of DNT signals, we currently do not make any guarantee that we will honor DNT signals.

Previously Expressed Preferences. You may change previously expressed preferences regarding how we use information you provide on or through this Site. For example, if you have provided your contact information and receive periodic emails from us, you may decide to stop receiving those emails by clicking the “unsubscribe” link in an email’s footer. Otherwise, please contact us using the information provided above.

 

How to Access, Update or Correct Your Personal Information

If you wish to access, update or correct your Personal Information, please contact us using the information provided above We will respond to you within a reasonable time and, in any case, within the time limits established by applicable law.  We may ask you for additional information to verify your identity.  In most cases, we will provide access and correct or delete any inaccurate information you discover.  In some cases, however, we may limit or deny your request if the law permits or requires us to do so or if we are unable to verify your identify.

 

Steps We Take to Safeguard your Personal Information

We maintain reasonable administrative, physical and technological measures to protect the confidentiality and security of personal information you submit on or through this Site. Unfortunately, no website, server or database is completely secure or “hacker proof.” We therefore cannot guarantee that your personal information will not be disclosed, misused or lost by accident or by the unauthorized acts of others.

 

How We Share Your Information With Others

  • With Third–Party Vendors. ASOP may share information collected through this Site with third-party vendors who act for or on behalf of ASOP. For example, we use third-party vendors to design and operate this Site; to conduct surveys; and to help us with our promotional efforts. These third-party vendors may need information about you to perform their functions.
  • With Other Users of this Site. You may be able to submit User-Generated Content on or through this Site. In this Policy, “User-Generated Content” or “UGC” refers to content that you post using the social networking tools we make available to you and that does not constitute “Feedback” (as that term is defined in our Terms of Use. Any personal information contained in UGC can be read, collected, or used by others. In addition, we may use UGC you submit for advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the content for such purposes. Therefore, you should have no expectation of privacy with respect to UGC you submit on or through this Site.
  • With Third-Party Social Media Platforms. We may use third-party social media platforms to offer you interest-based ads. To offer such ads, we may convert your email address into a unique value which can be matched by our partner company with a user on their platform. Although we do not provide any personal information to these platform vendors, they may gain insights about individuals who respond to the ads we serve.
  • In Aggregate or De-Identified Form. We use information collected through this Site to create a compiled, aggregate view of usage patterns. We may share aggregate information with third parties so we and they can better understand our user base. We may also share with third parties information about how particular individuals use this Site, but only on a de-identified basis (“Individualized Data”). Individualized Data is not personally identifiable, but it does reflect the usage patterns of a particular Site user, as opposed to Site users collectively. We may provide basic demographic information (gender and age) in conjunction with providing Individualized Data.
  • With Other, Carefully Selected Business Partners. From time to time, we may share your information with selected third parties for their own marketing purposes. Before doing so, however, we may offer you the opportunity to “opt out” or “opt in,” as required by applicable law.
  • As Part of a Business Transfer. Your information may be transferred to successor organization if, for example, we transfer the ownership or operation of this Site to another organization or if we merge with another organization. If such a transfer occurs, the successor organization’s use of your information will still be subject to this Policy and the privacy preferences you have expressed to us.
  • To Comply with Laws and Protect Our Rights and the Rights of Others. We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of this Site; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

 

Children Under the Age of Thirteen

We are proud of this Site and we strive to ensure that it does not offend people of any age. However, this Site is not intended for children or minors under the age of thirteen years without the permission of a parent or guardian. If you believe that a child has submitted personal information on or through this Site without the consent and supervision of a parent or guardian, please contact us using the information above so that we can take appropriate action.

 

This Site may contain links to websites operated by other organizations, including websites operated by our third-party service providers and other third parties. For example, if you click on an advertisement on this Site, you may be taken to a website that we do not control.

This Policy does not apply to information collected on any of these third-party websites.  When you access third-party websites through a link on this Site, please take a few minutes to review the privacy policy posted on that site.

 

European Data Protection Law

This section applies only to individuals who are located in the European Economic Area whose personal information may be collected through the Site. Nothing is this section is intended to bind ASOP in respect of the personal information of any other individual.

For the purpose of applicable data protection laws in the European Union (including the General Data Protection Regulation (2016/679)), ASOP is the data controller of your personal information.  For queries, contact us at our information listed below.

Our Legal Grounds for Using Your Personal Information

We will only use your personal information when the law allows us to do so. Most commonly, we will use your personal information as described here and in the box, below:

 

  • Where it is necessary for our legitimate interests (i.e. we have a business or commercial reason for using your information) and your interests and your fundamental rights do not override those interests (“Our legitimate interests”);
  • Where we need to comply with a legal or regulatory obligation (“Compliance with our legal obligations”); or
  • Where you consent (“Consent”).

 

We may process your personal information for more than one legal ground depending on the specific processing purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information.

 

Purpose Legal Ground(s) Legitimate Interest(s)

(if applicable)

To comply with our legal and regulatory obligations under applicable law Compliance with our legal obligations N/A
Operate the Site and improve the content, functionality and usability of the Site

 

 

Our legitimate interests

Efficiently fulfilling our legal and contractual duties; providing high quality client service

 

To customize our Site’s content and layout Our legitimate interests

 

Consent (where this involves the use of cookies; please see our Cookie Notice

 

Providing high quality client service

 

Respond to your questions, comments and requests you have made through the Site (including our digital marketing tools)

 

Our legitimate interests Providing high quality client service
Contact you with our newsletter that we believe will be of interest to you (but only if you have chosen to receive these communications)

 

Our legitimate interests

 

Your consent

Providing high quality customer service; keeping our services relevant; marketing our services

 

Contact you with information and notices related to your use of the Services

 

Your consent

 

Our legitimate interests

Providing high quality customer service; marketing our services; fulfilling our legal and/or contractual obligations

 

Invite you to participate in surveys and provide feedback to us (unless you have chosen not to receive such invitations)

 

Our legitimate interests

 

Your consent

Providing high quality client service; keeping our services relevant, effective and of high quality; defining types of clients for new services or offerings; marketing our services

 

Ensure our mailing lists are accurate, current and do not contain multiple entries for the same individual

 

Our legitimate interests

 

Compliance with our legal obligations

Providing high quality client service; keeping our services relevant, effective and of high quality; fulfilling our legal and/or contractual obligations

 

Monitor and analyze usage, trends and activities related to the Site to better understand your needs and interests; Demonstrate the effectiveness of our site to grantors and sponsors, as required by contract

 

Our legitimate interests

 

Compliance with our legal obligations

Providing high quality client service
To administer and protect the security of our business and IT infrastructure, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

 

Our legitimate interests

 

Compliance with our legal obligations

Efficiently fulfilling our legal and contractual duties; complying with regulations that apply to us; developing and improving the network security, efficiency and technical specification of our IT systems and infrastructure
As part of any proposed mergers and acquisitions involving ASOP

 

Our legitimate interests Expanding and developing our business; ensuring the future success of our business
To assert our rights in contracts to which we are a party and to establish, exercise or defend legal claims in which we are involved Our legitimate interests

 

Contract performance

 

Compliance with our legal obligations

 

Efficiently fulfilling our legal and contractual duties; complying with regulations that apply to us; to establish, exercise or defend legal claims

 

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal ground which allows us to do so.

Your Rights

Subject to any local or national law exceptions, if you are a resident of the European Economic Area (“EEA”) or your personal information is processed in the context of the activities of our London office, you have certain rights:

  • Access. Subject to certain exceptions, you have the right to request a copy of the personal information we are processing about you, which we will provide to you in electronic form.
  • You have the right to require that any incomplete or inaccurate personal information that we process about you is amended.
  • In certain circumstances, you have the right to request that we delete personal information that we process about you.
  • Restriction. You have the right to request that we restrict our processing of your personal information where: (a) you believe such information to be inaccurate, (b) our processing is unlawful but you oppose the deletion of your personal information, (c) we no longer need to process such information for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because we require the information in connection with legal claims, or (d) you have objected to the processing of your personal information.
  • Portability. You have the right to request that we transmit the personal information we hold in respect of you to another data controller, where this is (a) personal information which you have provided to us, (b) the processing is by automated means, and (c) we are processing that information on the basis of your consent or in order to perform our obligations under a contract to you.
  • Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.
  • Withdrawing Consent. If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time. This includes cases where you wish to opt out from marketing messages that you receive from us.
  • Making a Complaint. You may make a complaint at any time with the national data protection authority in the EU country where you are based. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us.

 

You may contact us at the information listed below at any time to exercise any of the rights which apply to you. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights).

 

Cross-Border Data Transfers

We transfer personal information to jurisdictions as necessary for the purposes described above.  In particular, our Site is hosted on servers located in the United States. To the extent permitted by law, such submission also constitutes your consent for the cross-border transfer.

With respect to transfers from the EEA to the United States and other non-EEA jurisdictions, we implement standard contractual clauses as approved by the European Commission, and other appropriate solutions to address cross-border transfers as required or permitted by Articles 46 and 49 of the General Data Protection Regulation.  Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us.

 

Privacy Rights in Other Jurisdictions

You may have rights in relation to your personal information under applicable data privacy laws in other jurisdictions. If you wish to exercise any such rights, please contact us using the contact information below.

Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us:

 

For the USA:

Attn: Marty Allain, ASOP Foundation Board of Directors Chair

1050 K Street NW, Suite 400

Washington DC 20001

info@buysaferx.pharmacy

 

This Policy May Change

This Policy describes ASOP’s current policies and practices with regard to the information we collect through this Site.

We are continually improving and adding to the features and functionality of this Site and the services we offer through this Site. As a result of these changes (or changes in the law), we may need to update or revise this Policy. Accordingly, we reserve the right to update or modify this Policy at any time, without prior notice, by posting the revised version of this Policy behind the link marked “Privacy Policy” at the bottom of each page of this Site. Your continued use of this Site after we have posted the revised Policy constitutes your agreement to be bound by the revised Policy. However, we will honor the terms that were in effect when we gathered data from you.