Privacy Notice

What does the Orsini Specialty Pharmacy Privacy Policy cover?

This Privacy Policy applies to information not covered by our Notice of Privacy Practices, which sets forth the use of patient information. This Privacy Policy instead describes the policies and procedures of Orsini Specialty Pharmacy (“Orsini,” “we,” “our,” or “us”) on the collection, use, and disclosure of other information through: your use of our website, https://www.orsini.com; the services, features, and content linking to this Privacy Policy (the “Site”); and that we otherwise collect from you as a customer, employee, or contractor (including, without limitation, for human resources, employment, benefits administration, health and safety, and other business-related purposes) (together with the Site, our “Services”). We value and respect the privacy of our customers, Site visitors, and our employees (including job applicants, and any owners, directors, officers, or medical staff members of Orsini, collectively “Personnel”) (“user,” “you,” or “your”). The purpose of this Privacy Policy is to provide you with information about our policies and procedures and to describe the choices you can make about our use of your information. When you use the Site or otherwise engage with our Services, including without limitation, browsing the Site, using any information, or submitting any content or Personal Information (as defined below) via our Services, you are consenting to the collection and use of your information as described in this Privacy Policy. If you do not agree to be bound by this Privacy Policy or any subsequent modifications, you should not access or use our Services or disclose any personal information through our Services.

We may update this Privacy Policy at any time, by posting the amended version to the Site. This Privacy Policy is binding on all those who access, visit, and/or use our Services, including all Personnel, whether acting as an individual or on behalf of an entity. We suggest that you review this Privacy Policy carefully. If you are a patient, you can learn more about our privacy practices by reviewing our Notice of Privacy Practices.

What information do we collect?

Personal Information

This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”) gathered when you are using, accessing, or otherwise engaging with our Services. Personal Information is information that identifies, relates to, describes, can reasonably be associated with, or can reasonably be linked to a particular individual or household.

We collect information from you both when you provide it voluntarily and also automatically when you use our Services. For example, we collect Personal Information (such as first and last name, company name, home address, e-mail address and/or telephone number) that you provide when you visit our Services; participate in promotions; fill out a survey or questionnaire; sign up for a program or newsletter; submit a job application; contact us via phone, email, or other means; or otherwise interact with Orsini or our Services.

We may collect the following categories of Personal Information from you, depending on your interactions with our Services and the choices you make, as further described below:

• Identifiers: Your name, email address, telephone number, postal address, date of birth, location, unique personal identifier, educational history, and Internet Protocol (IP) address.
• Company Information: Professional or employment-related information including but not limited to your company and job title/position.
• Sensitive Personal Information:[Social security number, state identification card, or passport number, financial account information, racial or ethnic origin, personal information regarding your health, sexual orientation information, postal address, educational history, and bank account information.] User Data: Any data entered voluntarily into a contact or other form on the Site.
• Internet or Other Electronic Network Activity Information:
  • Browse history. Data about the web pages you visit.
  • Search history. Data about the search terms you enter.
  • Device, connectivity, and configuration data. Data about your device and nearby networks, including regional and language settings
• Geolocation Data: Data about your device’s location, which is inferred from your IP address.
• Protected Health Information. When you communicate us regarding our services, we may obtain and access Protected Health Information (“PHI”) as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). We are required to comply with federal healthcare privacy and security rules, such as HIPAA and the Health Information Technology for Economic and Clinical Health (“HITECH”) Act, when receiving and processing your PHI. Our use and disclosure of PHI is governed by separate terms and conditions between Orsini and our customers. You can learn more about our PHI data practices and obligations under our Notice of Privacy Practices. PHI should only be submitted through our Services as permitted or required for use of our Services.

Generally, you control the amount and type of information you voluntarily provide to us when using our Services. You are not required to provide us with any Personal Information as a visitor to our Services. You must provide us with certain Personal Information, including your name, email address, company name, and telephone number, to make a request for information or otherwise communicate with us via our Services. We will offer your choices when we ask for Personal Information whenever reasonably possible. Any information you provide may be combined with demographic and other information that is available in order to allow us to better communicate with you and enhance your experience. If we combine or associate information from other sources with Personal Information that we collect through our Services, we will treat the combined information as Personal Information in accordance with this Privacy Policy.

Computer Information Collected; Tracking Technologies

We also collect Personal Information automatically when you use the Site. For example, we collect Personal Information from you and any devices (including mobile devices) when you: use the Site, provide us information on a web form, otherwise correspond with us, or engage or connect with our Services.

Computer Information Collected. We, and our third-party partners, collect non-personally identifiable usage data over time and across different websites (“Usage Information”) via cookies, web beacons, and similar technologies as further described in the “Tracking Technologies” section below when you visit the Site. Usage Information includes information about our visitors (including, for example, any customers, potential customers, and/or Personnel) and how they use the Site, including browser type, the website you were visiting before you visited the Site, time of day and your IP address, your mobile device advertising identifier and similar device identifiers. We, and our third-party partners, may use Usage Information for a variety of purposes, including to improve the Site.

Tracking Technologies. We and our third-party service providers may use cookies, web beacons and other tracking technologies to gather Usage Information about visitors and how they use the Site. We use this information to improve our Services, and for other business purposes. We and our third-party service providers also use Cookies (as defined below) and other technologies to enhance your online experience.

The Site uses “Cookies,” which are small pieces of information stored by your browser on your computer’s hard drive. The Cookies are used to connect your computer with information stored about your preferences, and we may use Cookies to recognize your web browser, determine how and when you visit the Site, and identify areas of the Site you have visited. You can find more information about cookies and how they work at www.allaboutcookies.org. We do not use Cookies to store any of your personal or financial information on your computer.

Most web browsers can be set to disable the use of Cookies, and you can choose whether to accept Cookies by changing the settings on your browser or device, as discussed further below in “Your Rights and Choices Regarding Your Personal Information.” If you would prefer not to receive Cookies, you can also alter the configuration of your browser to prevent your browser from accepting new Cookies. If you choose to have your browser refuse Cookies, it is possible that some features of the Site will not function properly, and you may not be able to participate in certain activities or receive a presentation tailored to you. We never place Personal Information in Cookies.

We or our third-party partners may use invisible pixels or beacons on the Site to count how many users access or use certain pages, features, or content. This information is collected and reported in the aggregate. We may use this information to improve our current Services offerings, develop new products or services, and target information to you that may be helpful and useful to you based upon your use of the Site.

Information Third Parties Provide About You

In addition, we also collect Personal Information about you from third parties in connection with our Services, including from the following sources:

• Service providers (including hosting providers);
• Data analytics service providers;
• Email, and other communications service providers;
• Customer service providers;
• Advertising providers;
• Social media platforms; and

For purposes of this Privacy Policy, information regarding your children that you (the parent) provide to Orsini is treated in the same manner as information collected about you.

How Do We Use and Share Personal Information?

Your Personal Information is used by Orsini to enhance your relationship with us, respond to your requests, tailor offerings to you, communicate with you about products, services, special offerings and events or programs offered by us or our marketing partners that may be of interest to you. Orsini may also use this information to analyze and manage its businesses. Aggregate data (which does not allow an individual to be identified, contacted or located) is collected from online and offline facilities and may be used to enhance our ability to communicate with you, and for internal analysis and management purposes.

We generally process your information when we need to do so to fulfill a contractual obligation or where we or someone we work with needs to use your Personal Information for a reason related to their business. These legitimate interests are further detailed in the table below. We only process Personal Information for these interests after considering the potential risks to your privacy.

Information collected through use of our Services:

Sharing Your Information

We share non-Personal Information with third parties at our discretion. We do not sell or rent Personal Information with third parties, unless ordered by a court of law, and have not done so in the past twelve (12) months. In addition, we do not knowingly sell or rent any Personal Information of consumers under 16 years of age with third parties and have not done so in the past twelve (12) months. Information submitted to us is available only to employees responsible for managing this data. In connection with our Services, we may share your Personal Information with certain third parties who we engage to help us run our business and perform the services, including under the following circumstances.

With our Service Providers

• Software and Service Providers. We may share your Personal Information with service providers who help us to administer and provide our Services (for example, a web hosting company whose services we use to host our platform for the Site). In addition, we may share your Personal Information with software and service providers we use to manage and process your information (such as, but not limited to, providers of payment processing software).
• Human Resources Software and/or Service Providers. We may also share your Personal Information with service providers who support Orsini’s management of Personnel (for example, a company utilized to assist with recruiting and evaluating potential job applicants, or a company whose services we use to manage timekeeping, payroll, and employee benefits).
• Product-related Service Providers. We may also share your Personal Information with product-related service providers who warehouse product, personalize product and perform order fulfillment services on behalf of Orsini.
• Marketing Service Providers. We may also utilize marketing service providers to communicate with you and/or advertising service providers that we use to assist with prospective marketing partners and advertisers and to provide personalized advertising on third-party websites.
• Web Analytics Providers. We may share your information with web analytics providers who monitor and analyze the use of our Site (including Hubspot). For more information about Hubspot, please visit https://legal.hubspot.com/privacy-policy.

In Connection with Business Transfers

In the event that a part or all of Orsini (or the assets of Orsini) is subject to a merger or acquisition with/by another company, we may share information with the other company in connection with the transaction, and your Personal Information may be included among the transferred business assets. Such acquiring company’s right to use your Personal Information shall be limited to the terms of the Privacy Policy as it existed at the time that the Personal Information was collected unless additional notice is provided to you.

To Comply with Laws

Additionally, we may also disclose specific information with third parties: (i) where necessary to comply with applicable law, regulation, legal process, or governmental request; (ii) where it is necessary in connection with the Site, our services or products; (iii) to investigate or prevent fraud or abusive or unlawful uses or activities, violations of the terms governing use of our Site and services and/or law, rule, or regulation; and/or (iv) to protect the interests or safety of our visitors and guests, Orsini, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. We may share Personal Information with the Internal Revenue Service and Other Taxing Authorities.

We will not license, sell or provide your Personal Information to any unaffiliated third party except as provided by this Privacy Policy, permitted by law or with your consent.

How Personal Information Is Protected

The security of your data is important to us, and we strive to use commercially reasonable means to protect your data. No method of transmission over the Internet is 100% secure, however, and we cannot guarantee or warrant that such techniques will prevent unauthorized access to your data. Any transmission of your information is at your own risk. By using the Site, you acknowledge and accept these risks.

How Long We Store Your Information

We will retain your Personal Information only for as long as commercially reasonable for the legitimate business purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to provide our services (such as responding to a customer request made through the Site) and to comply with our legal, accounting, or reporting obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. Additionally, we may continue to store your Personal Information contained in our standard internal back-ups.

We also will retain Usage Information for internal analysis purposes. Usage Information is generally retained for a shorter period of time, except when Usage Information is used to strengthen the security or to improve the functionality of the Site or our or products, or we are legally obligated to retain Usage Information for longer periods.

Your Rights and Choices Regarding Your Information

Marketing Preferences

By providing your telephone number and/or email address to us, or otherwise communicating with us, you may receive periodic mailings, telephone calls or e-mails from us and/or our affiliates with information on products or services, discounts, special promotions, upcoming events or other offers from us or our marketing partners, including automated marketing messages. You may opt out of receiving future communications from us at any time. For example, you may opt out of e-mail communications by clicking the “Unsubscribe” link at the bottom of the e-mail received, and you may opt out of Orsini text communications by replying “STOP” if you receive Orsini text communications, or you may opt-out of either communication by contacting us as set forth in under “How to Contact Us” below to unsubscribe from future emails. Please allow sufficient time for your preferences to be processed.

Even if you opt out of receiving marketing messaged, we may still contact you for transactional purposes like confirming or following up on a service request. You may later opt back into getting market communications from us.
Cookies; How We Respond to “Do Not Track” Signals

As noted above in “What Information Do We Collect?” above, you can choose whether to accept cookies by changing the settings on your browser or device. If you choose to disable cookies, however, your experience with the Site may be impaired and some features may not work as they were intended.

Additionally, Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the preferences or settings page of your web browser. These features are not yet uniform, however, so we do not currently respond to such features or signals. Therefore, if you select or turn on a “do not track” feature in your web browser, we and our third-party providers may continue collecting information about your online activities as described in this Privacy Policy.

You can choose to limit the data that third-party services share with us using the options provided to you by the applicable third-party service. You can also disconnect your use of the Site from the third-party service at any time using the options provided to you by the applicable third-party service. Please note, however, that if you disconnect from the third-party service, that will not delete the data we may have previously collected while you were connected.

State-Specific Rights

Depending on where you live in the United States, you may have certain rights with respect to Personal Information that we have collected and used under certain circumstances, which may include the following:*

• The right to request the following information regarding our use of your Personal Information:
  • The categories of your Personal Information that we have collected;
  • The purposes for which we have collected or used such Personal Information;
  • The categories of sources for the Personal Information we have collected about you;
  • The categories of third parties with whom we have shared your Personal Information;
  • If we have disclosed your Personal Information for a business purpose, the categories of third parties with whom we have disclosed your Personal Information; and
  • If we have sold or shared your Personal Information, a list identifying the Personal Information categories that each category of recipient purchased or received.
• The right to receive a copy of your Personal Information.
• The right to request correction of any inaccurate Personal Information.
• The right to request us to erase your Personal Information when we no longer need such data in connection with the Site (subject to certain exceptions that may apply under applicable law).
• The right to opt out of sales or sharing of your Personal Information. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us. For clarity, we do not sell or rent Personal Information with third parties.
• The right to limit the use or disclosure of your sensitive Personal Information to that use which is necessary to provide the services or goods. To exercise the right to limit the use or disclosure, you (or your authorized representative) may submit a request to us by visiting the following Internet web page link: https://info.orsinispecialtypharmacy.com/consumer-rights-request
• The right to appeal our refusal to take action on a previous rights request.
• The right to non-discrimination for exercising your rights.

* If you are a resident of a jurisdiction where one or more of these rights are granted to you under applicable law, and you wish to exercise any such rights listed above, please contact us by either:

• Phone: 1-(800) 410-8575
• Web: https://info.orsinispecialtypharmacy.com/consumer-rights-request

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. Please understand that we are required to verify your request and may require you to provide some information to enable us to carry out such verification. 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.

Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

When you, or someone legally authorized to act on your behalf, make a consumer request related to your Personal Information, you can expect the following:

1. We will verify your identity. You will need to provide us with certain information so that we can verify that you are who you say you are. Which information may depend on the type and sensitivity of information subject to the request.
2. We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at the webpage or phone number listed above.
3. We will respond to your request within the legally required amount of time. If necessary, we may need additional time to respond where allowed by law, but we will reply either way within the legally required period and, if we need an extension, we will explain why.
4. In certain cases, a request may be denied. For example, if we cannot verify your identity or if providing you information could create an unreasonable risk to someone’s security (for example, we do not want very sensitive information disclosed inappropriately). If we deny your request, we will explain why we denied it.

Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Transfer of Data; Special Notice to Non-U.S. Users

Your information, including Personal Information, may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States for processing.

We will take all step reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Sensitive Personal Information

Subject to the following paragraph, when you use, access, or otherwise interact with the Site, we ask that you not send us, and you not disclose, any sensitive Personal Information as this term is defined under applicable data protection and privacy laws (for example, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership or precise geolocation) on or through the Site or otherwise to us.

If you send or disclose any sensitive Personal Information to us, you consent to our processing and use of such sensitive personal data in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive Personal Information, you must not submit such content to the Site.

Orsini’s Policy on Children’s Information

The Site is not intended for use by, and does not knowingly solicit or collect personally identifiable information online from, children under the age of 13 (“Children” or “Child”) without prior verifiable parental consent. By using the Site, you represent that you are at least 13. If you do not meet this age requirement, please do not access or use the Site. If you are a parent or guardian and you are aware that your Child has provided us with Personal Information, please contact us through one of the methods listed under “How to Contact Us” below. If we learn that a Child has submitted Personal Information online in contravention of these measures (i.e., without verification of parental consent), we will take all reasonable measures to delete such information from our servers.

For more information about the Children’s Online Privacy Protection Act (“COPPA”), which applies to websites that direct their services to children under the age of 13, please visit the Federal Trade Commission’s website: https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions. Linked Sites

Our Services may contain links to other websites and access to content, products, and services of third parties, including our affiliates, strategic partners, and other entities with which our connection consists only of a hyperlink (“Linked Sites”). This Privacy Policy does not apply to the practices of third parties that we do not own or control including but not limited to the Linked Sites. You understand that these Linked Sites are not under our control and are not subject to our Privacy Policy, and you should exercise caution when deciding to disclose any Personal Information through those Linked Sites. You should review the privacy policy of any site linked to or framed within a Linked Site prior to providing any information on or to that site. You agree and acknowledge that we will not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any content, services, resources, or goods on or through any such Linked Site. You acknowledge that your use and access of these Linked Sites is solely at your own risk.

How to Contact Us

You can update your communication preferences and information by contacting us at the e-mail address or phone number below. Additionally, if you have questions or concerns about our use of your Personal Information or this Privacy Policy, please do not hesitate to contact us through any of the methods listed below.

Phone:  1-(800) 410-8575

Fax:      1-(847) 725-8104

Email:   patientcare@orsinihc.com

Mail:     Orsini Specialty Pharmacy

ATTN: Patient Care Privacy Officer

1111 Nicholas Blvd

Elk Grove Village, IL 60007