Effective Date: April 15, 2020
Date of Last Review: April 15, 2020
MED-Project USA and Affiliates
1800 M Street NW, Suite 400 South
Washington, D.C. 20036
The following disclosures identify our information gathering and usage practices.
Personal Information We Collect and Why
When you visit the Site, we automatically collect information about your device, including web browser information, IP address, time zone, location, and some of the cookies that are installed on your device. We refer to this automatically-collected information as “Device Information.”
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer. Cookies often include an anonymous unique identifier. For more information about cookies, please visit http://www.allaboutcookies.org.
- “Log Files” track actions occurring on the Site and collect data, including IP address, browser type, Internet service provider, referring/exit pages, location, and date/time stamps.
- “Web Beacons,” tags,” and “pixels” are electronic files used to record information about how you browse the Site.
When you log in to our Site, request or attempt to request a mail-back package, or call our call center and request a mail-back package, we collect certain other information about you. That information includes your name, your address, and the type of mail-back package(s) you are requesting.
Consequentially, we also collect:
- Date of your request.
- Mail-back package tracking numbers.
- Shipment dates.
- Mail-back package date(s) received.
- Information about the type of mail-back package requested.
For purposes of this Policy, the above information is referred to as “Request Information.”
How We Use Your Personal Information
Device Information we collect is used to improve and optimize our Site. For example, Device Information can help us generate analytics about how our customers browse and interact with the Site and allow us to determine the success of our marketing and advertising campaigns. We use Device Information to screen for potential risk and fraud (for example, your IP address).
Request Information we collect is used to fulfill any requests placed through the Site, including arranging for shipping.
Request Information is used to:
- Communicate with you.
- Send you mail-back packages for unwanted medications or sharps you wish to dispose of that are covered by our program.
- Screen requests for potential risk or fraud.
- Provide you with information or outreach and education relating to our services.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
How We Share Your Personal Information
We may share your Personal Information with third parties for the business purposes of providing our services to you and running our program. When we disclose Personal Information for the foregoing business purposes, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. We may share Personal Information with third parties from the following categories:
- State and County Governmental entities, such as the Department of Health.
- Pharmaceutical Companies who fund the program services.
- Operations Fulfillment Vendors.
- Third-party auditors engaged to monitor program.
We will share your Personal Information as required to comply with applicable state, local, or federal laws and regulations. For example, we may share your information to respond to a subpoena, search warrant, or other lawful request for information that we receive, or to otherwise protect our rights and interests.
How We Store Your Personal Information
MED-Project stores your Personal Information carefully and with due consideration. We encrypt and store Personal Information on secure cloud-based servers.
Personal Information Collection Source Categories
Information collection source categories include:
- The consumer directly
- Internet service providers
- Data analytics providers
- Government entities
- Operating systems and platform
Changes to this Policy
MED-Project reserves the right to update this Policy from time to time to reflect changes to our practices, or as required by law. MED-Project accepts your continued use of the Site after any changes are made as your agreement and consent to the changes regarding this Policy.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint or submit a request, please contact us by any of the following methods:
MED-Project USA and Affiliates
1800 M Street NW, Suite 400 South
Washington, D.C. 20036
Rights of California Consumers
Note: If you are not a California resident, the following rights may not apply to you.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- If we disclosed your Personal Information for a business purpose, the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested.
- Take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at (833) 633-7765.
- Emailing us at email@example.com.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may appoint an authorized agent by providing us with a notarized affidavit.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative,
- Verification requirements may include name, address and/or phone number
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We do not, and have never, sold Personal Information at any time.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you for goods or services, which are offered free of charge to all participants, including through granting benefits or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.