Effective date January 30, 2020
1. DATA PROTECTION AT ASAP
1.1 ASAP Drug Solutions (“ASAP”) respects individual privacy and is committed to the protection of confidential data we maintain. ASAP is committed to the collection, use, and disclosure of personal information in a manner consistent with applicable law. For these reasons, ASAP has developed a privacy program designed to respect and protect data privacy rights.
2.1 For purposes of this Statement, the following definitions shall apply:
2.1.a “Agent” means any third party that uses personal information provided by ASAP to perform tasks on behalf of, and at the direction of, ASAP.
2.1.b “ASAP” means ASAP Drug Solutions and any affiliated companies.
2.1.c “Personal information” are data about an identified or identifiable individual that are within the scope of the applicable US law or regulation.
2.1.d “Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, union membership, religious or philosophical beliefs, that is related to an individual’s financial account or consumer report, or that concerns the health of an individual. In addition, ASAP will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
3. PURPOSE FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
3.1 ASAP collects, uses and discloses your Personal Information in its normal course of business for the following purposes:
3.1.a Establishing and maintaining communications with you;
3.1.b Where you have requested a service from ASAP, assisting you in the completion of your application, the assessment of your eligibility for any such requested service, the processing and maintenance of the service, as well as any applicable renewal of such service;
3.1.c Responding to your inquiries about applications, accounts and other services;
3.1.d Making proposals for future service needs;
3.1.e Allowing our affiliated companies to notify you of certain products or services offered by our affiliated companies;
3.1.f Processing transactions through service providers;
3.1.g Meeting legal, security, processing and regulatory requirements;
3.1.h Protecting against fraud, suspicious or other illegal activities; and
3.1.i Compiling statistics for analysis of our sites and our business.
4. WHAT INFORMATION WE COLLECT
4.1 The information gathered by ASAP from this Site falls into two categories: (1) information voluntarily supplied by individuals and (2) tracking information gathered as visitors navigate through our Site.
4.1.a Information voluntarily provided by you
When using this Site, you may choose to provide us with information to help us serve your needs. The Personal Information that we collect will depend on how you choose to use this Site. Generally, we collect identifying information, biometric and biological information as part of the services, and similarly related transactional information which you voluntarily provide.
4.1.b Where you request information about our services
If you request further information about our services, we require you to submit your name, e-mail address, and physical address so we may send you the material you have requested, and to enable us to identify if you have an existing relationship with ASAP.
4.1.c Where you register with us and/or request services
If you register with the Site, or request a service available on the Site, we may ask you for your name, e-mail address, country, telephone number and the reason for your communication, as well as information about your position and organization and such other information as is reasonably necessary so that we can provide you with the service. On the data submission form, we shall indicate which information is optional and which information is mandatory. This information can include information you provide on applications or other forms, which may include your name, address, email address, and payment information.
4.2 Any Personal Information that you send us will be used for the purpose indicated on the Site or in this Privacy Statement.
4.3 Following an inquiry into receiving services from us, if you decide to proceed, we will collect Personal Information necessary to proceed with the transaction, such as your name, address, post code, contact telephone number, e-mail address, billing address or payment details, and other Personal Information as relevant to the product. We will use your Personal Information to administer your account, process requests etc. and generally manage your relationship with us.
4.4 Website Navigational Information
As you navigate the Site, we may also collect information through the use of commonly-used information-gathering tools, such as cookies and web beacons (collectively “Website Navigational Information”). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Site (such as the web pages viewed and the links clicked).
4.4.a.ii There are different kinds of cookies with different functions:
- Session cookies: these are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.
- Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
- First-party cookies: the function of this type of cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between ASAP’s servers and your computer’s hard drive. They are not used for anything other than personalization as set by you. These cookies may be either Session or Persistent cookies.
- Third-party cookies: the function of this type of cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the Third-party’s server and your computer’s hard drive. These cookies are usually Persistent cookies.
4.4.a.iii Except as described in this Privacy Statement, we do not use third-party cookies on our Sites, although we do use third-party web beacons (please see the section on Web Beacons below).
4.4.a.v The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized, ASAP’s Sites are not compatible with DNT and so do not recognize DNT settings.
- Where strictly necessary
These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, services you have asked for, such as obtaining a quote or logging into your account, cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
These cookies collect information about how visitors use a Site, for instance which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to the Site, all of which enables us to see how visitors use the Site in order to improve the way that our Site works. These cookies do not collect information that identifies a person, as all information these cookies collect is anonymous and is used to improve how our Site works.
These cookies allow our Site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, a Site may be able to remember your log in details, so that you do not have to repeatedly sign into your account when using a particular device to access our Site. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have requested such as viewing or commenting on content on the Site. The information these cookies collect is usually anonymized.
4.4.a.vii Please consult your web browser’s ‘Help’ documentation or visit https://aboutcookies.org. for more information about how to turn cookies on and off for your browser.
4.4.b Web Beacons
The Site may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about user’s usage of the Site and interaction with e-mails from ASAP. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Site tied to the web beacon, and a description of a Site tied to the web beacon. We use web beacons to operate and improve the Sites and e-mail communications. We may use information from web beacons in combination with other data we have about our clients to provide you with information about ASAP and our services. We will conduct this review on an anonymous basis.
4.4.c IP Addresses
When you visit our Sites, ASAP collects your Internet Protocol (“IP”) addresses to track and aggregate non-Personal Information. For example, ASAP uses IP addresses to monitor the regions from which users navigate the Sites. IP addresses will be stored in such a way so that you cannot be identified from the IP address.
5. DISCLOSURE OF INFORMATION TO OTHERS
We do not disclose any Personal Information about you collected by this Site to any third parties except as stated in this Privacy Statement, as otherwise permitted by law, or authorized by you.
Third parties to whom we disclose information are required by law and contractual undertakings to keep your Personal Information confidential and secure, and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances, in compliance with all applicable legislation, which purposes are as follows:
5.1.a To provide the products and services you have requested from us;
5.1.b To notify you or allow our affiliated companies to notify you of certain products or services offered by our affiliated companies;
5.1.c For legal, regulatory, and employment services;
5.1.d To process transactions through data processing service providers;
5.1.e If the information is a credit card number, to process credit card payments—through third party payment processing, clearing and settlement systems in association with various banks; and
5.1.f If these third parties wish to use your Personal Information for any other purpose, they will have a legal obligation to notify you of this and, where required, to obtain your consent. Contact us at firstname.lastname@example.org for more information on these third parties.
5.2 Affiliate Sharing
In the normal course of performing services for our clients, Personal Information may be shared within ASAP and its affiliates for research and statistical purposes, system administration and crime prevention or detection. When you supply us with information containing third party Personal Information (names, addresses, or other information relating to living individuals), we will hold and use that Personal Information to perform general screening and other services for you on the understanding that the individuals to whom the Personal Information relates have been informed of the reason(s) for obtaining the Personal Information, the fact that it may be disclosed to third parties such as ASAP, and have consented to such disclosure and use.
5.3 Service Providers
5.3.a Because a number of the service providers we use are located in the United States, including certain ASAP affiliates, your Personal Information will be processed and stored inside the United States, and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under US laws.
5.3.b ASAP’s service suppliers adhere to the same protections regarding the collection, use, and retention of data as we do.
5.4 Business Transactions
As we continue to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. Also, if either ASAP itself or substantially all of ASAP assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third-party purchaser in these circumstances.
5.5 Other Legally Required Disclosures
ASAP preserves the right to disclose without your prior permission any Personal Information about you or your use of this Site if ASAP has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of ASAP, employees, other users of this Site, or the public; (b) enforce the terms and conditions that apply to use of this Site; (c) as required by a legally valid request from a competent governmental authority; or (d) respond to claims that any content violates the rights of third-parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental request
In this Privacy Statement, the purposes identified above and in “Collection, Use and Disclosure of Personal Information” will be referred to as the “Identified Purposes.”
6. CALIFORNIA PRIVACY RIGHTS
6.1 California’s Civil Code section 1798.100 et seq. provides residents of California a number of rights as they relate to Personal Information. These are the “right to know”, the “right to delete”, and the “right to opt-out”.
6.2 Right to Know.
You may request ASAP provide you the specific pieces of personal information that ASAP has about you; categories of personal information we have collected about you; categories of sources from which the personal information is collected; categories of personal information that ASAP sold or disclosed for a business purpose about you; categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling personal information. Please note that much of the information you may request is already specified in this Statement. Should you wish to make a request, please see the section below which explains how to do so. If you do not have an account with ASAP, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request.
6.3 Right to Delete.
California law gives residents a limited right to request deletion of their Personal Information. However, this right is limited by a number of exceptions. Fundamentally, if ASAP has a permissible need to retain Personal Information, we are not under an obligation to delete such information, even when requested. Generally, we retain Personal Information so we may complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; debug to identify and repair errors that impair existing intended functionality of our online properties; enable solely internal uses that are reasonably aligned with your expectations based on your relationship with ASAP; comply with a legal obligation; or otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which your provided the information. As such, we generally do not accept requests to delete Personal Information. However, we will respond to requests to remove Personal Information from some of our systems as a part of a request to close or otherwise disable a membership account. If you would like to request deletion of Personal Information, please see the section below which explains how to do so. If you do not have an account with ASAP, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request.
6.4 Right to Opt-Out.
ASAP does not sell your Personal Information to third parties, and as such there is no need for you to opt-out of the sale of your Personal Information. However, we do share Personal Information with third parties for marketing purposes and permit our marketing partners to collect data directly from you. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes at any time by submitting a request in writing to our contact address below. Please note that this opt-out does not prohibit disclosure made for non-marketing purposes.
6.5 Designating an Authorized Agent.
California law permits California residents to designate an agent to manage their rights under California law. If you would like to designate an agent to manage your privacy preferences, you may do so using the mechanisms noted below under “Exercising California Privacy Rights”. Note that If you do not have an account with ASAP, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request. We will also need sufficient Personal Information about your authorized agent to be able to identify him/her. As part of this process, you must have permission from your authorized agent to disclose their Personal Information to us for the purpose of acting as your agent.
California law does not permit ASAP to discriminate against you because you exercised any your rights under this title.
6.7 Exercising California Privacy Rights.
If you are a California resident and would like to exercise any of your rights you may do so by emailing us at compliance@ asapdrugsolutions.com, or calling us at +1 (562) 624-2720.
7. DATA SECURITY
ASAP will employ reasonable safeguards to protect personal information in its possession from loss, misuse, unauthorized access, disclosure, alteration or destruction. For personal information subject to electronic storage or transmission, ASAP maintains an internal, private, and secure network that is monitored to prevent unauthorized access. Both electronic and paper-based records holding personal information are maintained in access controlled facilities.
Any questions or concerns regarding the use or disclosure of personal information should be directed to the Compliance Officer at the address given below. We will respond to any reasonable and valid complaint within a reasonable time. ASAP will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Statement.
9. CONTACT INFORMATION
Questions or comments regarding this Statement should be submitted to the ASAP Compliance Officer at the following address:
ASAP Drug Solutions
Attention: ASAP Compliance Officer
This Statement may be amended from time to time. Appropriate public notice will be given concerning such amendments when they are made.