INSITO HEALTH PRIVACY POLICY
Effective Date: 08/15/2024
This Privacy Policy describes how Insito Health, Inc. and its affiliates (“Insito Health”) collect, use, disclose, and protect your personal information in connection with the Company’s owned and operated websites, currently available at insitohealth.com and medfinder.com (collectively, the “Site”) and the related services or events we provide (collectively with the Site, the “Services” or the “Insito Health Services”).
Our Services currently focus on finding a pharmacy that has your prescription in stock. To do this, we need prescription-related information, such as the medication’s name, dose, quantity, and whether you have a brand preference for the medication. Knowing the prescriber’s name also helps us in this process because pharmacies sometimes like to know it when discussing medication availability, but providing the prescriber’s name to us is optional. We do not request, require, or use information about health or medical conditions — only details about the specific prescription you would like us to find. Our Consumer Health Data Privacy Policy has more specific detail about our handling of prescription-related data. We do not provide health or medical advice.
TABLE OF CONTENTS
Information We Collect
Use of Information
Disclosure of Information
Your Rights and Choices
Data Retention
Protection of Information
Children
Updates and Changes to This Policy
Contacting Us
1. INFORMATION WE COLLECT
a. Information You Provide to Us:
You may provide the following types of information to us:
Identifiers, such as name, email, and phone number;
Prescription-related information, such as the medication’s name, dose, quantity, and whether you have a brand preference for the medication;
Commercial information, such as:
a record of the content on our Site that you experience;
details about your purchases and other business interactions with us, responses to surveys, and participation in our events;
Audio or visual information, such as recordings of calls or other interactions with customer service;
Zip code and rough geolocation (inferred from your IP address);
Internet or other electronic network activity information, as described in the Cookies and Other Technology section below; and
Inferences based on any of the above.
Payment information, such as credit card number, is stored and processed by a third-party payment processor, not us.
b. Cookies and Other Technology
Through our online properties, we and third parties may collect information from your computer or other device by automated means such as cookies, web beacons, local storage, JavaScript, mobile-device functionality and other computer code. This information may include unique browser identifiers, IP address, browser and operating system information, device identifiers (such as advertising identifiers), other device information, Internet connection information, as well as details about your interactions with the relevant Site, email or other online property (for example, the URL of the third-party website from which you came, the pages on our website that you visit, and the links you click on in a website). In some cases (such as cookies), the tools described here involve storing unique identifiers or other information on your device for later use.
c. Information From Third Parties
We may also receive personal information from third parties, including pharmacies, prescribers, drug manufacturers, service providers, affiliates, and partners such as analytics and advertising partners, payment processors, other users of the Services, and publicly available sources, such as social media websites and online reviews sites.
We may combine the information we collect about you from these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information as Personal Information.
2. USE OF INFORMATION
We and our service providers use the information described above for the following purposes. Not all information is used for all purposes.
Manage and improve the Services generally, including to identify pharmacies near you that could fill your prescription;
Process your registration and verify your information;
Customize content, preferences, and advertising on our Site, across the Internet and elsewhere;
Send you confirmations, updates, security alerts, and support and administrative messages;
Conduct sales and marketing;
Conduct business operations such as auditing, security, fraud prevention, invoicing and accounting, analytics, and research and development;
Protect against, identify, investigate, and respond to misuse of the Services or other unlawful behavior;
Address legal requirements;
Establish, exercise, or defend our legal rights; and
Create aggregated or de-identified information.
3. DISCLOSURE OF INFORMATION
We may disclose your information as follows. Not all information is subject to all of these disclosures.
To visitors of our Site, if you review our Services. If you review our Services on third-party platforms, such as Trustpilot, we may display your name, along with any information you provide in your review or for public display on that third-party platform (if applicable), such as the profile photo you make publicly available on that third-party platform. The information you provide in those reviews, including any medications you state that you are taking, could be incorporated into the reviews and testimonies displayed on the Site. Those reviews and testimonies may be directly linked to your review on a third-party platform, which may contain more information than we display directly on our Site.
To patients, prescribers, and pharmacies. We disclose information as necessary to provide the Services, which includes disclosing your identity and prescription-related information to pharmacies. It may also involve disclosing such information to your prescriber. If you use the Services to find a prescription for another person (such as a family member), we may also disclose that fact and details about your use of the Services to that person.
To vendors and service providers: We disclose information to companies that provide services to us, such as providers that analyze data or provide customer service, data storage, marketing, analytics, advertising, security, or fraud prevention. We may engage a third party to host or operate any aspect of the Services, including any mechanism through which we send or receive communications, such as our email systems and our Site.
To affiliates: We may disclose information to current or future parents, subsidiaries, affiliates, and other companies under common control or ownership with Insito Health.
In connection with legal matters: We may disclose information when we believe disclosure is appropriate due to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency; or as otherwise required by law.
For the protection of Insito Health and others: We may disclose information when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our employees, our customers, or others; and to enforce our contracts.
In connection with corporate transactions: We may disclose your information as part of, or to take steps in anticipation of, a sale of all or a portion of our business, a divestiture, merger, consolidation, asset sale, bankruptcy, or other significant corporate event.
In other situations: We may also disclose your information in other situations where legally permitted.
We may use and disclose appropriately aggregated or de-identified information for any purpose.
4. YOUR RIGHTS AND CHOICES
a. Marketing Communications
You can unsubscribe from our marketing emails via the unsubscribe link provided in the emails or by emailing us at privacy@insitohealth.com. To opt out of receiving text messages from us at a particular number, reply STOP to us from that number. Please note that it may take us some time, consistent with our legal obligations, to process your request. Even if you opt out from receiving marketing messages from us, you will continue to receive administrative emails from us, such as order confirmations, updates to our policies and practices, or other communications regarding our relationship or transactions with you.
b. Cookies and Other Similar Technologies
As mentioned above, you may be able to set your browser to refuse certain types of cookies, or to alert you when certain types of cookies are being used. Some browsers offer similar settings for HTML5 local storage and other technologies too. However, if you block or otherwise reject all cookies, local storage, JavaScript or other technologies, certain websites may not function as expected.
Additionally, on certain pages of our Site, we may allow third-party advertising technologies (e.g., ad networks and ad servers such as Google, Bing, and Meta) that use cookies and similar technologies to collect data to deliver relevant and targeted content and advertising to you on the Services and other websites you visit and applications you use. The ads may be based on your activity over time and across other websites and online services and may be tailored to your interests.
The use of cookies or other tracking technologies that may be placed on devices you use to access our Services by non-affiliated third parties is governed by the privacy policies of those third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your devices to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising, or customize Google display network ads, visit the Google Ads Settings page.
You can also refer below in “Rights Regarding Your Information” for additional ways to opt out of targeted advertising activities under applicable law.
We may also use third-party web analytics services on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using information collected on our Site for analytics, you may install the Google Analytics Opt-out Browser Add-on available here and visit our Site only from the browser in which you have installed it. If you receive email from us, we may use certain analytics tools to collect data such as when you open our message or click on any links or other content our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
We do not respond to do-not-track signals.
c. Rights Regarding Your Information
Depending on where you live, you may have the right to make certain requests related to your personal information. For example, you may have the right to ask us to:
Provide you access to or a copy of certain personal information.
Correct or update personal information.
Delete certain personal information.
Restrict or opt you out of certain uses of your information, including for targeted advertising, sale, or certain profiling purposes, if any.
Withdraw any consent that you previously provided (without affecting the lawfulness of processing based on consent before the withdrawal takes effect);
Provide you with certain details regarding the processing of your information.
Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information in order to provide the Services to you, so we can’t delete it while still providing you with the Services.
We may take reasonable steps to verify your identity before responding to certain requests, which may require verifying your name and email address. If we are unable to verify your identity, we may be unable to respond to your requests.
If you wish to exercise any privacy rights, or raise a complaint about our handling of your personal information, please contact us as described at the end of this Privacy Policy. Your state law may allow you to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with a legally sufficient signed, written permission to make such requests (in a form acceptable to us) or an appropriate power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law.
Depending on applicable law, you may have the right to appeal our decision to deny your request. We will provide information about how to exercise that right in our response denying the request. You may also have the right to lodge a complaint with a supervisory authority.
Residents of some jurisdictions have a right to opt out of what the laws in those jurisdictions call a “sale” of personal information, as well as to opt out of certain uses and disclosures of personal information for certain targeted advertising or “profiling” purposes. To start the process of exercising these rights, they can email us as described at the end of this Privacy Policy with their name and the type of request they are making.
5. DATA RETENTION
We keep your information until after we determine it is no longer necessary for the purposes described in this Privacy Policy and we are not legally required to retain it for longer.
6. PROTECTION OF INFORMATION
To help protect personal information, we have put in place physical, technical, and administrative safeguards. However, we cannot assure you that data that we collect under this Privacy Policy will never be used or disclosed in a manner that is inconsistent with this Privacy Policy.
7. CHILDREN
Parents and legal guardians are welcome to use our Services to find prescriptions for their children, but children themselves cannot use our Services. If you are a parent or legal guardian and think your child under age 13 (or a higher age threshold where applicable) has given us personal information, please contact us at privacy@insitohealth.com so that we can delete it.
8. UPDATES AND CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time, such as to reflect changes in our practices or for legal reasons. We will post those changes here or on a similarly accessible page.
9. CONTACTING US
If you have any questions or comments regarding our privacy policy and practices, or to submit a request or complaint, please email us at privacy@insitohealth.com or use the contact details below:
Insito Health, Inc.
110 Beverly St, #521, Boston MA, 02114