Privacy Policy

Effective Date: This privacy policy (this “Privacy Policy”) is effective and was last updated as of June 15, 2023.

This Privacy Policy applies when accessing, using, or otherwise interacting with RxData.net (our “Website”), our subscription SaaS database of pharmaceutical pricing, reimbursement and access information (our “Platform”) and any other feature or service offered by RxData, Inc. and its affiliates (“RxData”, “us”, “our,” or “we”) that posts or includes a link to this Privacy Policy (collectively, the “Services”). This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of personal information we receive from users of our Services and your choices.

Please read this Privacy Policy carefully. By accessing or using the Services, you consent to our Privacy Policy and our collection, use, and sharing of your information as described in this policy and our Terms of Use.

Important note on the applicability of this Privacy Policy: This Privacy Policy primarily applies to visitors of our Website. Access and use of our Platform is restricted to our clients, who are generally business entities that use the Platform in the conduct of their businesses pursuant to contracts with us. Data privacy laws generally distinguish between a “controller” of personal information (which determines the purposes and means of processing of personal information) and a “processor” of personal information (which processes personal information on behalf of a controller). With respect to any personal information processed by us in the operation of our Platform, our clients are the controllers of such personal information and we are a processor of such personal information, and our processing is subject to the terms and conditions of our contracts with our clients and their privacy policies.

If you are an authorized user of our Platform accessing and using the Platform on behalf of one of our clients, then the client you are engaged by is the controller of any personal information processed by us in the operation of the Platform and the privacy policies of that client govern your personal information. To the extent any data privacy laws apply to such personal information, and you desire to make any choices or exercise any rights available to you under such laws or under the privacy policy of such client, including any described herein such as rights of access, correction, deletion, or limitation on processing, then you should address requests directly to our client that you are engaged by. If requests are directed to us, to the extent we are able to identify the client you are engaged by then it is our practice, in accordance with applicable laws and our contracts with clients, to refer any request to the client for instructions on responding. It will expedite a response if you make any requests directly to the client you are engaged by, which will in accordance with their policies and any applicable data privacy laws provide us with instructions pertaining to any personal information of yours that we process on such client’s behalf.

1. Information We Collect and How We Collect It

We may collect information from you both directly and automatically when you use or visit the Services. Some of this information may be considered “personal information” under various applicable laws. We consider information that identifies you as a specific, identified individual to be personal information (such as your name and email address), and we treat additional information, including IP addresses and cookie identifiers, as “personal information” where required by applicable law. Note that RxData may de-identify personal information so that it is non-personal, such as by aggregating it or converting it to a code, sometimes using a function commonly known as a “hash.” We will treat de-identified information as non-personal to the fullest extent allowed by applicable law. If we combine non-personal information with personal information, then we will treat the combined information as personal information under this Privacy Policy.

RxData collects information in the following ways:

2. How We Use Your Information

We may use non-personal information for any purpose, including for advertising, research, and marketing purposes. We also use information that we collect, including personal information and Usage Information, as disclosed in this Privacy Policy and as follows:

3. How We Share Your Information

We may aggregate, de-identify, and/or anonymize any information collected through the Services such that the related information is no longer linked to your personal information.

In addition, we may share the information we have collected about you, including personal information and Usage Information, as disclosed at the time you provide us with information or your consent, and as described in this Privacy Policy, including:

4. Analytics

RxData works with third party business partners such as analytics providers to provide us with information regarding the use and effectiveness of the Services. We allow these companies to place tracking technologies like cookies and web tags on the Services, and they may otherwise collect or have access to Usage Information and other information about you. Some of these parties may collect personal information over time when you interact with the Services or other online websites and services. We may share information, typically information that has been aggregated or de-identified, Usage Information, and location information with analytics providers and other such third parties.

We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the Services and report on activities and trends. This service may also collect information about the use of other websites, apps, and online services. You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

5. How We Respond to “Do Not Track” Signals

Do Not Track (“DNT”) signals offered by some web browsers are settings that request that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and/or other web services you encounter while browsing to stop tracking your activity. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we may not alter our practices when our systems receive a “Do Not Track” signal from a visitor’s browser, except as specifically required by law. You can learn more about Do Not Track at www.allaboutdnt.com.

6. Third Party Content and Links

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including, but not limited to, any third-party websites, services and applications (and the information or content contained therein) ("Third-Party Services") that may be linked to or from the Services and/or that you elect to access through the Services. When you navigate away from our Services to another site, this Privacy Policy is no longer in effect. Those Third-Party Services may use their own cookies or other tracking technologies, may independently collect information from you or about you, and match your data with data from other sources and use your data in ways other than described in this Privacy Policy. Your browsing and interaction on any Third-Party Services is subject to such Third-Party Services’ own rules and policies, which we encourage you to review prior to providing them with your information.

7. Your Choices About the Information We Collect

You may opt out of marketing communications as set forth below.

8. Security of Your Information

If you are a resident of certain jurisdictions, you may have additional rights with respect to your personal information. For example, please see “International Users; EU, EEA and UK”. If you submit a request to us and we ascertain that the data privacy laws of your jurisdiction apply to us, then subject to any conditions and qualifications of such law we will endeavor to respond to such request in compliance with such laws. Please direct any requests to us at [info@RxData.net].

9. General Audience Services

The Services are not intended for children younger than the age of 18. We do not knowingly collect or solicit personal information from children younger than the age of 18.

10. Changes to this Privacy Policy

To the extent allowed by applicable law, we reserve the right to change this Privacy Policy at any time. We will inform you by posting a notice on the Services. We may also provide notice to you in other ways, such as through contact information you have provided. Your continued use of the Services after the effective date of the revised Privacy Policy will constitute your consent to those changes to the fullest extent allowed by applicable law. However, we will provide notice and obtain your consent (opt-in or opt-out) if required. Note that you may no longer be able to use certain or any features of the Services if you do not consent to the revised Privacy Policy.

11. International Users; EU, EEA and UK

We are a US-based company so if you are located outside of the United States, please be aware that the information that we collect from you will be transferred to, and stored at, a destination outside of your country. By accessing and using our Services, you understand and acknowledge that your personal information will be transferred from your location to our facilities and servers in other jurisdictions, including the United States. By using our Services or providing us with any information, you fully understand and unambiguously consent to this transfer to, and processing, usage, sharing, and storage of your information in other jurisdictions, including the United States, which may have different or less protective privacy laws than those in your country. As a result, this information may be subject to access requests from governments, courts, or law enforcement in the United States and other countries according to the laws in those jurisdictions.

The laws in some jurisdictions, including in the European Union and European Economic Area and the United Kingdom, require companies subject to such laws to provide certain information including the legal grounds they rely on to process “personal data” as defined under those laws. To the extent you are a visitor to our Website and a resident of one of those jurisdictions and those laws apply to us, RxData is a data “controller” for processing of personal data and our legal grounds for processing your personal data are as follows:

Legitimate Interests. In many cases, we process personal data on the ground that it furthers our legitimate interests in commercial activities, such as described in “How We Use Your Personal Information” above, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals.

Legal Compliance. We process personal data in certain ways to comply with our legal obligations.

Honor Our Contractual Commitments to You. Our processing of personal data may be required to meet our contractual obligations, if any, to you, or to take steps at your request in anticipation of entering into a contract with you.

Consent. Where we collect personal data and have obtained your consent, we may process your personal data within the scope of that consent.

Subject to the applicability to us of certain laws, such as those of the jurisdictions described above, you may have certain rights with regard to your personal data. These rights may include the rights to (1) access or rectify your personal data or request its deletion, (2) request a restriction on the processing of your personal data, (3) object to the processing of your personal data, or (4) exercise other rights with respect to your personal data, such as withdrawal of consent to processing. While we strongly encourage you to first raise any questions or concerns about your personal data by contacting us directly, you may have a right to lodge a complaint with the relevant supervisory authority under any such applicable law. Many of the rights described here are subject to significant limitations and exceptions under any such laws, even if they are applicable. Please direct any requests to info@rxdata.net.

As noted above, if you are a user of our Platform on behalf of one of our clients, then such client is the “controller” for processing of your personal data under the laws described above and you should refer to such client’s privacy policy for information on, and how to exercise any of your rights with respect to, your personal data.

12. Contact Us

If you have any questions, comments, or concerns regarding our Privacy Policy and/or practices, please send an email to: info@rxdata.net. You may also contact us at RxData, Inc., 251 West 30th street, Floor 5, New York, NY 10001, United States, Attn: Data Privacy.