Our Consumer Health Data Privacy Policy

Effective Date: March 31, 2024

We at Alora Pharmaceuticals, LLC, along with our subsidiaries and affiliates (collectively, “Alora”), respect your concerns about privacy, particularly as it concerns data related to your past, present or future physical or mental health status. Alora operates one or more websites (collectively, the “Alora Websites”), including alorapharma.com, acellapharma.com, avionrx.com, osmotica.com, sovpharm.com, trigenlab.com, rxglendale.com, verticalpharma.com, as well as the websites for our products and related services.

This Consumer Health Data Privacy Policy describes the types of information we may collect from you, how we collect and may use that information, and with whom we may share it.

This Consumer Health Data Privacy Policy only applies to consumer health data under the State of Washington’s “My Health My Data Act.” For information about Alora’s general privacy practices and policy, which will also apply to your health data, please review our Privacy Policy.

Consumer Health Data We May Obtain

We may obtain consumer health data about you, which is personal information that is linked or reasonably linked to you that identifies your past, present or future physical or mental health status. This can include the following types of information:

  • Individual health conditions, treatment, diseases, or diagnosis;
  • Social, psychological, behavioral, and medical interventions;
  • Health-related surgeries or procedures;
  • Use or purchase of prescribed medication;
  • Bodily functions, vital signs, symptoms, or measurements of the information related to health conditions, treatment, diseases, or diagnosis;
  • Diagnoses or diagnostic testing, treatment, or medication;
  • Reproductive or sexual health information;
  • Biometric data;
  • Precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies;
  • Data that identifies you as seeking health care services; or
  • Other information that we, or a data processor contract with, processes to associate or identify you with any of the data described above. This information may be derived or extrapolated from non-health information (such as proxy, derivative, inferred, or emergent data by any means, including algorithms or machine learning).

Sources of Consumer Health Data

We may collect consumer health data directly from you when you visit our website(s), for example, by filing out a form on our website(s), or when you use our products or services or otherwise interact with us.

We may also collect consumer health data by automated means, such as cookies or web beacons, which may include Internet Protocol addresses, unique device identifiers, browser characteristics, device characteristics, operating systems, language preferences, referring URL’s, information on actions taken, and dates and times of activity.

We may also obtain consumer health data from our resellers or other third-party partners, or acquire consumer health data from public sources or from third-party sources, such as our advertising and market research partners.

Purposes of Collecting and Using Your Consumer Health Data

We may collect and use your consumer health data for the following purposes:

  • Provide the products and/or services you request from us;
  • Enrollment in discount or savings programs;
  • Enrollment in services offered on our website(s);
  • Send you news, updates, promotions, product information, event announcements, and other marketing communications;
  • Provide you with technical support and/or troubleshooting related to the use of our website(s);
  • Provide you with customer service;
  • Provide you with advertising tailored to your interests;
  • Comply with legal and regulatory obligations;
  • Release de-identified and/or non-personally-identifying information in the aggregate;
  • For other purposes pursuant to and consistent with your consent.

How We May Share Consumer Health Data With Others

We may disclose any of the consumer health data described above to our service providers as necessary to provide the products and/or services to you and otherwise operate our business. We may also share consumer health data with our affiliates, which includes Acella Pharmaceuticals, LLC, Avion Pharmaceuticals, LLC, Glendale Pharmacy LLC, Glendale Pharmacy – Frisco, LLC, Osmotica Pharmaceutical US LLC, Sovereign Pharmaceuticals, LLC, Trigen Laboratories, LLC and Vertical Pharmaceuticals, LLC. In addition, we may share consumer health data with our business partners, regulatory or government agencies (e.g., the U.S. Food & Drug Administration), or any entity that acquires Alora or any of its affiliates through a sale, merger or other transaction. We may also share your consumer health data as required by legal obligations, such as in response to a subpoena or court order, or otherwise with your consent, as permitted by applicable laws.

Your Rights

You may submit requests to us at privacy@alorapharma.com to inquire about any of the following, or to take the following actions:

  • To confirm whether we are collecting, sharing, or selling your health data, and (if applicable) a list of all third parties and affiliates with whom we have shared or sold your consumer health data along with an email address or other online mechanism you can use to contact these third parties;
  • To access a copy of your consumer health data that we have collected, shared or sold;
  • To withdraw your consent for us to collect or share your consumer health data; and
  • To have your consumer health data deleted.

Depending on the type of request, we may need to verify your request before we can fulfill it. Please note that certain exceptions may apply to these rights (e.g., we may be unable to honor a request to delete if it conflicts with our legal obligation to retain and report adverse event data).

You also have the right to appeal any decisions we make with regard to your rights request. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

Policy Changes

Alora may change this Consumer Health Data Privacy Policy from time to time and at any time, without notice, within the sole, independent, absolute and uncontrolled exercise of its discretion. When we update the policy, we will indicate the date the policy was last updated. Alora encourages visitors to frequently check this page for any changes to its Consumer Health Data Privacy Policy.

Contact Information

If you have any questions or comments about this Consumer Health Data Privacy Policy, please contact us at privacy@alorapharma.com.

SUPPLEMENT TO CONSUMER HEALTH DATA PRIVACY POLICY FOR NEVADA CONSUMERS

This Supplement to the Consumer Health Data Privacy Policy applies to Nevada consumers for purposes of providing additional disclosures required by Nevada’s consumer health data privacy law.

The foregoing consumer health data disclosures and rights also apply to Nevada residents. In addition, Nevada residents also have the right to review and amend any consumer health data we maintain about them. Nevada residents can escalate unsuccessful appeals of consumer rights requests to the Nevada Attorney General at https://ag.nv.gov/Complaints/File_Complaint. Also, please note that third parties may collect consumer health data over time and across different Internet websites or online services when you use our website.

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