Find My Meds Consumer Health Data Privacy Notice
Effective Date: November 12, 2024
This Consumer Health Data Privacy Notice supplements SixD Inc.’s (“Company”, “we”, “us”, and “our”) Privacy Policy for Find My Meds and applies specifically to “Consumers” as defined under applicable U.S. privacy laws regarding Consumer Health Data (collectively, the “CHD Privacy Laws”).
This CHD Privacy Notice describes our practices regarding the collection, use, sharing and disclosure of Consumer Health Data. Any capitalized terms not defined in this CHD Privacy Notice shall have the meanings given to them in our Privacy Policy. This CHD Privacy Notice does not supersede, replace, or otherwise amend our Privacy Policy.
Consumer Health Data Collected
For purposes of this CHD Privacy Notice, Consumer Health Data (“CHD”) is defined as under applicable CHD Privacy Laws and includes personal information that is linked or reasonably linkable to a Consumer and that identifies the Consumer’s past, present, or future physical or mental health status.
We may collect and share the following types of CHD:
  • Individual health conditions, treatment, diseases or diagnosis inferred by your prescription information
  • Health-related surgeries or procedures inferred by your prescription information
  • Use or purchase of prescribed medication
  • Diagnoses or diagnostic testing, treatment, or medication inferred by your prescription information
  • Data that identifies a consumer seeking health care services
We do not “sell” your CHD and as stated in our Privacy Policy, we do not allow any CHD to be shared for marketing or retargeting purposes. We will not authorize any third party to collect CHD over time and across different Internet websites or online services when a Consumer uses the Platform.
Why the Consumer Health Data is Collected & How it is Used
We collect, process and use each of the CHD described above for the following purposes:
  • Requests and Inquiries: We may use your CHD to process, evaluate, and respond to your requests and inquiries. For instance, if you provide us with information to register for an account, we will use the information you provide to process your registration. If you request certain information from us, we will use your CHD to process and respond to your request.
  • To Provide You with the Platform and Services: We may use your CHD for purposes of fulfilling requests for our services, including delivering the Platform to you if you have registered for an account and enabling you to find the pharmacies nearest you with the ability to refill your prescription.
  • Manage Our Relationship with You: We may use your CHD to manage your account with us, and to send you important information regarding our relationship with you or regarding the Platform, such as information about changes to our terms, conditions, policies, and other administrative information.
  • Internal Business Purposes: We may use your CHD for our internal business purposes, including without limitation, to help us operate, evaluate, and improve the quality of the Platform; to improve our services; to better understand those individuals that utilize the Platform; to verify your identity; to prevent, protect against, identify, or address fraud, unauthorized activity, claims, liabilities, and other wrongdoing; to provide you with customer service; and to generally manage our business.
  • De-identify Data: We may use your CHD to create anonymous, aggregated or deidentified data by removing from the records any identifiers that make the information personally identifiable to you.
  • Legal Requirements, Industry Standards, and Contractual Obligations: We may use your CHD as we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this CHD Privacy Notice, our Privacy Policy and Terms of Service; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; (vii) for research and education and (viii) to allow us to pursue available remedies or limit the damages that we may sustain.
Sources of CHD
We collect CHD directly from Consumers, as well as from caregivers, families, and friends who you give access to your profile through the Platform.
Retention Period
We retain your CHD for the period reasonably necessary to provide our Platform and services to you and for the period reasonably necessary to support our business operational purposes, including but not limited to comply with our legal obligations and for our legal positions (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
Our Sharing of CHD
We may share each of the categories of CHD listed above with the following entities:
  • Those You Direct Us to Share Personal Information With: The Platform allows you to share your CHD with those you direct us to, such as pharmacies nearest you with your consent. In such case, we may disclose your CHD with these pharmacies according to your preferences. Please note that once we disclose your CHD to such pharmacies, we are no longer responsible for such information, and we are not responsible for the information practices of such pharmacies.
  • Third-Party Service Providers: We may share your CHD with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Platform or assist us in providing functionality on the Platform, provide data analytics on the Platform, send out e-mails about the Platform and our services and to process payments.
  • Corporate Transactions: We reserve the right to transfer or assign CHD that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
  • Legal Purposes: We disclose your CHD as we believe to be necessary or appropriate to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose CHD as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share CHD as required to pursue available remedies or limit damages we may sustain.
We may also share de-identified and anonymized data with our third-party partner, Novo Nordisk.
Exercising Consumer Data Rights
You may delete your account at any time by using the “Delete Profile” option in the Platform. If you do so, all of your data, including your CHD will be irrevocably deleted from our systems.
Consumers have certain rights under applicable CHD Privacy Laws with respect to the collection and use of their CHD. If you are a Washington or Nevada resident, you have the rights to:
  • Confirm whether we collect, share or sell your CHD;
  • Access such CHD, including a list of all third parties with whom we have shared or sold the CHD;
  • Withdraw consent from our collection and sharing of CHD; and
  • Delete your CHD.
If you are a Connecticut resident, you have the rights to:
  • Confirm whether or not we are processing your CHD and access such CHD;
  • Correct inaccuracies in your CHD, taking into account the nature of the CHD and the purposes of the processing of your CHD;
  • Delete CHD provided by or obtained about you;
  • Obtain a copy of your CHD we process, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance, where the processing is carried out by automated means.
Please note that we do not engage in processing your CHD for purposes of targeted advertising, selling your CHD; or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
You may exercise any of the aforementioned rights by [insert mechanism for receiving data subject rights requests], or by referring the “Contact Us” section below.
You may only make a verifiable request related to your CHD. The verifiable request must:
  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected CHD; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
If you maintain an online account with us, we may verify your identity for a request through the normal account authentication process, meaning you will need to sign on with your username.
We reserve the right to verify your identity in connection with any requests regarding CHD to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals to exercise rights with respect to that information. We cannot respond to your request or provide you with CHD if we cannot verify your identity or authority to make the request and confirm the CHD relates to you.
In the event we deny your request, you may appeal our denial by contacting us in the same manner by which you submitted your request.
Changes to this CHD Privacy Notice
We reserve the right to amend this CHD Privacy Notice at our discretion and at any time. When we make material changes to this CHD Privacy Notice, we will notify you by email or posting a pop up banner on the Platform, and posting an updated CHD Privacy Notice on our Platform and listing the effective date of such updates.
Contact
For questions about this CHD Privacy Notice, please contact us at legal@findmymedsapp.com.