Last Updated: March 31, 2024 

Before getting into Our Consumer Health Data Privacy Policy below and what it covers, here are a few things you should know. The BuzzRx website (“BuzzRx.com” or the “Website”) and the BuzzRx mobile application (the “BuzzRx App,” and collectively with the Website, the “Site”) are owned by Watertree Ventures LLC, d/b/a BuzzRx (“BuzzRx”, “We”, “Our”, or “Us”) and BuzzRx is the sole owner of information collected on this Site.

In order to provide discounts on prescription medications and other related pharmacy goods and services, We may need to collect, and, in certain circumstances, share your Consumer Health Data (“Health Data”). This Consumer Health Data Privacy Policy (“CHDPP”) describes what Health Data We may collect, use, and share about you, along with the purpose for Our collection, use and sharing of your Health Data. This CHDPP also describes the rights that you have in connection with the Health Data privacy laws enacted in Washington and Nevada.

Categories of Health Data We Collect

• Information about the prescription medications for which you search, browse, or request a coupon. This Health Data may reveal that you have a specific mental or physical health condition, that you are seeking treatment for a specific mental or physical health condition, or are seeking treatment for someone else with a specific mental or physical health condition;

• Individual health conditions or status, treatment, diseases, or diagnosis;
• Diagnosis or diagnostic testing, treatment, or medication;
• Data that identifies a consumer seeking health care services, including reproductive or sexual health services;
• Your use, acquisition, or purchase of prescribed medication; and
• Precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies.

This Health Data may be combined with identifying information that We passively and automatically collect about you when you visit Our Site, such as your IP address, your Device ID or your unique advertising IDs, and personal information that you may actively provide to Us when requesting a coupon, such as full name, email address, phone number, and mailing address.

Categories of Sources of Health Data

Source: Information You Provide to Us

We collect Health Data that you, or someone on your behalf, provide directly to Us.

• In order to receive a coupon from Our Website or App, you will need to provide a prescription name.
• In order to receive medication pricing on Our Website or App, you will need to provide a prescription name.
• When you call Our customer service team and request medication pricing, you will need to provide a prescription name.
• When you email Our customer service team and request medication pricing, you will need to provide a prescription name.
• A healthcare provider, such as your physician, may send Us your Health Data, at your direction and on your behalf.

Source: Information We May Collect on Our Website or App Automatically

We may use third-party technologies, such as pixels, cookies and SDKs on Our Site that collect the personal information of visitors to Our Site such as pages where a consumer might share information about their health or medical condition, e.g., looking up prescription prices, requesting coupons, accessing our “Prescription Savings Categories” pages, etc. This information may reveal that a user has a specific physical or mental health condition, or is seeking treatment for someone in their household who has a physical or mental health condition.

Purpose for Collecting Health Data

We may collect and use all categories of Health Data listed above for the following business purposes:

As Stated or Agreed to at the Point of Collection. We collect Health Data for the purposes stated and agreed-to at the point of collection. For example, We use Health Data to deliver the prescription discount card/coupon requested by you.

To Provide Goods and Services. We use Health Data in order to provide Our goods and services to you, which you have requested. For example, you may request additional information from Us (including notifications about prescription refills), prices for prescription drugs in your area, the location of pharmacies in your area, or to deliver the prescription discount card/coupon requested by you.

Administration. We use Health Data for administrative purposes, such as facilitating transactions, order fulfillment, member support, and other related actions for providing Our services requested by you.

Categories of Health Data We Share

• Information about the prescription medications for which you search, browse or request a coupon. This Health Data may reveal that you have a specific mental or physical health condition, that you are seeking treatment for a specific mental or physical health condition, or are seeking treatment for someone else with a specific mental or physical health condition;

• Individual health conditions or status, treatment, diseases, or diagnosis;
• Diagnosis or diagnostic testing, treatment, or medication;
• Data that defines a consumer seeking health care services, including reproductive or sexual health services;
• Your use, acquisition, or purchase of prescribed medication; and
• Precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies.

This Health Data may be combined with identifying information that We passively and automatically collect about you when you visit Our Site, such as your IP address, your Device ID or your unique advertising IDs, and personal information that you may actively provide to Us when requesting a coupon, such as full name, email address, phone number and mailing address.

Categories of Third Parties and Specific Affiliates with Whom Health Data is Shared

We will share all of the Health Data listed above only to provide you with the goods or services that you have requested.

When We disclose your Health Data, BuzzRx ensures that its third parties are contractually bound to comply with federal and state requirements as to how to handle your Health Data, including data security safeguards to protect your Health Data. We may share all categories of Health Data listed above with the following categories of third parties and/or service providers:

• We may share Health Data with Our employees, subsidiaries, and affiliates who have a need to know the information and only to provide you with goods or services that you have requested.
  
  
  • We may share your Health Data with Our affiliate, Buzz Integrations LLC, for business and operational purposes that are necessary to provide you with the goods or services that you have requested. For example, this is necessary for Us to provide you with the lowest price possible for your prescriptions.
    
    
• We may use one or more service providers to safeguard, protect, store, and/or analyze data, which may incidentally include Health Data. We will ensure that this is done safely and securely. This includes information security vendors, data security vendors, and threat detection monitoring service providers.
  
  
• We may share your Health Data, name, address, telephone number, or email address with third party fulfillment vendors if you request a discount card and/or coupon to be texted, emailed, or mailed to you. This includes mail houses, printers, text, and email delivery services.
  
  
• We may use other companies including pharmacies, pharmacy benefit managers, and other healthcare providers, consumer privacy management software, and text and email delivery services to perform services that are necessary to providing you with the goods and services that you request from Us. These other companies may be supplied with or have access to your Health Data solely for the purpose of providing these services on Our behalf. They do not have any independent right to use or disclose your Health Data. We have contracted with Our service providers to protect any such Health Data.
  
• BuzzRx may transfer its user database, including Health Data contained therein, to a third party who acquires all, or substantially all, of the assets or stock of BuzzRx whether by merger, acquisition, reorganization, bankruptcy, receivership, or otherwise. We may provide Health Data to the subsequent owner(s), including as part of any due diligence process.

Washington and Nevada Consumer Rights

This provides additional terms that apply to residents of Washington and Nevada. In the event of a conflict between the CHDPP and Our Privacy Policy, this CHDPP shall take precedence for Washington and Nevada residents. In this CHDPP only, any capitalized terms not defined in this CHDPP have the meanings set forth in the Washington My Health My Data Act (the “WMHMDA”) or Nevada Senate Bill 370 (collectively, “Consumer Health Data Privacy Laws”).

Your Right to Consent to the Collection of Your Health Data

The Consumer Health Data Privacy Laws require that We obtain your consent before We collect or share your Health Data for a purpose that is not necessary to providing you with the goods or services that you have specifically requested.

Your Right to Consent to the Sale of Your Health Data

The Consumer Health Data Privacy Laws give Washington and Nevada consumers the right to consent to the sale of their consumer Health Data. "Sell" or "sale" is defined as the exchange of Health Data for monetary or other valuable consideration. BuzzRx does not sell Health Data.

Your Right to Consent to the Sharing of Your Health Data

The Consumer Health Data Privacy Laws give Washington and Nevada consumers the right to consent to the sharing of their Health Data. "Share" or "sharing" is defined as to release, disclose, disseminate, divulge, make available, provide access to, license, or otherwise communicate orally, in writing, or by electronic or other means, Health Data by a regulated entity or a small business to a third party or affiliate.

Based on this definition, We share Health Data through Our use of third-party technologies, such as pixels, cookies and SDKs on Our Site that collect the Health Data of visitors to Our Site. We use your Health Data collected and shared only to the extent necessary to provide you with the goods or services that you have requested.

Complete List of Washington and Nevada Consumer Rights

• Your Right to Request Deletion of Your Health Data - You have the right to request that BuzzRx delete any Health Data which BuzzRx has collected about you in our records, including from our archived or backup systems.  We will comply with such request, and notify all affiliates, processors, contractors, and other third parties with whom We have shared Health Data of the deletion request.

• Your Right to Access Your Health Data - You have the right to confirm whether a company is collecting, sharing, or selling your Health Data and to access such data, including a list of all third parties and affiliates with whom the regulated entity or the small business has shared or sold the Health Data and an active email address or other online mechanism that the consumer may use to contact these third parties.

• Your Right to Provide Consent to Collect, Share, or Sell Your Health Data - You have the right to consent to the collection, sharing, or selling of your Health Data at any time (this is your right to “consent”). We may not collect, share, or sell your Health Data without your consent except to the extent necessary to provide you with the product or service that you have requested. You also have the right to withdraw consent to collect, share, or sell your Health Data.
  
  
• Your Right to Request a Complete List of Third Parties with Whom We Share Your Health Data - You have the right to request a complete list of third parties with whom We share your Health Data.

How to Exercise Your Rights

If you are a “consumer” as that term is defined by Washington My Health My Data Act (RCW 19.373.010(7)) or by Nevada law (NRS Chapter 603A Section 7) you have certain rights with respect to consumer health data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions.  To exercise your rights, you may submit your request to Us by contacting Us at any of the following:

Click here to make a Data Rights Request. You can also exercise the right to opt out of selling your Health Data and/or targeted advertising by broadcasting the global privacy control signal; use a browser equipped with the Global Privacy Control browser extension. To learn more about global privacy controls visit globalprivacycontrol.org. Note that due to technological limitations, if you visit Our Site from a different computer or device, you will need to rebroadcast the signal.

Send Us an email at: ConsumerRequests@BuzzRx.com

Our toll-free telephone number: 844-749-1019 (available Monday to Friday 9am to 5pm EST)

Or write to Us at:

Consumer Health Data Privacy Rights

BuzzRx

1 East Broward Boulevard

Suite 300 West

Fort Lauderdale, FL 33301

The Verifiable Consumer Request

BuzzRx must request certain information from a consumer who submitted the request, to verify the consumer is actually the consumer about whom BuzzRx has collected certain Health Data. You must describe your request with sufficient detail to allow Us to properly understand, evaluate, and respond to your request.

When We receive your request to exercise your rights under the Consumer Health Data Privacy Laws: (a) We will acknowledge receipt of your request; (b) We will respond to your request within 45 days after receipt of your request. Depending upon the nature and complexity of your request, We may extend the initial 45 days by an additional 45 days, and, if We do extend Our time to respond, We will notify you of the extension within the initial 45-day period;  (c)  We will try to match the information you provide in making the request with information We already maintain about you; (d) if required to verify your identity, We may ask you to provide additional information; (e) We will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.

If you maintain an account with Us, We may use that account to respond to your request and/or verify your identity. If We are unable to verify your identity as required by applicable laws and regulations, We will decline to comply with your request, and let you know why.

When We Will Respond

Except as otherwise noted, We will try to respond to your request within 45 days of receipt of your verifiable consumer request. BuzzRx reserves the right to extend this initial 45 days by an additional 45-day period when reasonably necessary. If We require additional time, We will inform you of the reason and extension period. For data deletion requests, We will delete Health Data from our records not later than 30 days after authenticating the request and from archives and backups no later than 6 months after authenticating the request. 

Your Right to Appeal Our Decision

If We reject your request, you have the right to appeal Our decision. Within ninety (90) days of your receipt of Our rejection of your request, you may submit a communication to Us appealing Our decision to reject your request. You may submit your appeal communication using the methods that We provide for the submission of consumer requests. In your appeal communication, please provide as much detail as possible about why you believe that We have rejected your request in error. It would be helpful if you were able to cite specific sections of the consumer data privacy law and guidance that applies to you.

Once We receive your appeal submission, We will have forty-five (45) days to reconsider your request and provide a written explanation to you. If We reject your appeal, you have the right to contact your state attorney general. For more information about how to contact your state attorney general, please visit:

WA: https://www.atg.wa.gov/file-complaint

NV: https://ag.nv.gov/Complaints/File_Complaint/