California Consumer Privacy Rights
Effective Date: July 14, 2021
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), this section applies to any California residents about whom we have collected PII from any source, including through the use of our website or by communicating with us electronically, in paper correspondence, or in person.
For purposes of this section, “PII” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. PII does not include publicly available information or information that has been de-identified.
Information We Collect
We may collect the following categories of PII about you:
- Identifiers, which may include real name and alias; postal address; unique personal identifier; online identifiers as detailed below; Internet Protocol (“IP”) address; email address; telephone number; account number, name, and password; driver's license number, state or other government-issued identification card number; MAC address; and/or other similar identifiers;
- Biometric information, which may include voice recognition information; facial scans; and/or other similar biometric identifiers;
- Information relating to Internet activity or other electronic network activity, which may include cookie identifiers, clear gifs (a.k.a. web beacons/web bugs), browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, device platform, device version, and/or other device characteristics including your choice of settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”), CPU ID and type, build, model, manufacturer, operating system version, screen size, screen resolution, mobile network status, device locale, and carrier ID;
- Geolocation data, which may include GPS data; locational information based upon your IP address; cell network data; and/or other similar locational data; and which may be collected from various devices including your mobile device(s) or vehicle(s);
- Audio, electronic, or visual information, which may include records of calls to or from our customer service centers; and/or video surveillance information;
- Professional or employment-related information;
- Information not listed above and related to characteristics protected under California or federal law; which may include gender; race and ethnicity; language; religion; country of origin; marital status; military service/veteran status; and/or date of birth;
- Other PII not listed above and described in California Civil Code § 1798.80(e), which may include signature; physical characteristics or description; and/or bank account number credit card number, debit card number, and other financial or health information).
How We Use Your Information
We may collect or use PII from you for the following purposes:
- Internal analytics;
- Assessing third-party vendors/service providers;
- Audit, compliance, policy, procedures, or regulation;
- Billing, payment, and fulfillment;
- Customer claims and fraud investigation and prevention;
- Customer communications;
- Customer relationship management;
- General business administration;
- Marketing products and services;
- Financial reporting and accounting;
- Website optimization and maintenance;
- Systems and data security.
Sources of Collected Information
We may collect PII from the following categories of sources:
- Our customers, and prospective customers, including via our website, telephone, text message, postal mail, or other means;
- Our business partners;
- Our service providers, which includes affiliates, marketing/customer relationship management providers, social media, technology/website hosting providers, analytics providers, and systems administrators/security and fraud investigations providers;
- Third parties: Companies that collect publicly available information or business partners that collect information and provide to us pursuant to their privacy policies and terms of service.
We do not sell PII or otherwise provide PII to third parties, other than service providers receiving information to perform services on our behalf.
We conduct digital marketing for which we share a limited set of data that is gathered when you visit our website or other services. This includes sharing cookies and pixels, with third parties to allow you to see tailored digital advertisements. We may also share certain information to enhance our ability to communicate with you and provide you with promotional information. To the extent this activity is interpreted as included in California law's broad definition of “data sale,” we have provided you with opt-out rights as to that activity as further described in the “Notice of Right to Opt-Out of Sales” section below.
We may share your PII with the following categories of third parties:
- Advertising and marketing companies;
- Social media companies;
- Technology companies.
IWP does not collect or sell the PII of minors under 16 years of age.
Your Privacy Rights
If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your PII.
- Right to Know - You have the right to request what PII we collect, use, disclose, and/or sell, as applicable.
- Right to Delete - You have the right to request the deletion of your PII that is collected or maintained by us.
- Right to Opt-Out of Sales - You have the right to opt-out of the sale of your PII by us. You may review our Notice of Right to Opt-Out below.
- Right to Non-Discrimination - We may not discriminate against you because you have exercised any of the privacy rights described above. This right may be subject to the offers described in our Notice of Financial Incentives, which you may be reviewed below.
You may authorize someone to exercise the above rights on your behalf. Documentation will need to be provided to verify that you have requested an authorized agent to make a request on your behalf. Such documentation may include a Power of Attorney or other signed document. If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child.
We must be able to reasonably verify your identity and authority to exercise these rights before fulfilling a request. There are also various exclusions and exceptions that apply to these rights under applicable laws. So that we can verify your identity when you make a request, you will need to provide certain PII via webform or over the phone.
If you are a California resident and wish to exercise these rights, please utilize our Contact Us form, email us at privacy@IWPharmacy.com or call us toll-free at (888) 295-3989.
Notice of Right to Opt-Out of Sales
If you wish to opt-out of our sharing of the limited data that is gathered when you visit our websites and other web-based services for purposes of targeted digital advertising, you may do so by utilizing our Contact Us page, emailing us at privacy@IWPharmacy.com, or calling us toll-free at (888) 295-3989.
Please note that the effectiveness of your opt-out request may be limited by our ability to associate the cookies and/or pixels that we may collect from your web session with your identity, browser, device, and/or browsing session. As a result, your opt-out request will be more effective for future visits to the website if you:
- Utilize the same device that was used to exercise the opt-out request;
- Have not cleared cookies from your web browser;
- Are not using a private or "do not track" mode in your web browser;
- Provide the same PII that you provided previously.
We encourage you to re-submit opt-out requests from any other devices that you may be utilizing to visit our website.
How to Contact Us
If you are hearing or speech disabled, please dial 711 to reach us through the National Telecommunications Relay.
You may also write us at:
Attn: Privacy Officer
Injured Workers Pharmacy
P.O. Box 33
Methuen, MA 01844