Privacy Notice for California Residents
Last Updated: 4/29/2021
Information we collect
Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer ("personal information"). In particular, Therapeutic Research Center’s product websites including Pharmacist’s Letter, Pharmacy Technician’s Letter, Prescriber’s Letter, Hospital Pharmacist’s Letter, Hospital Pharmacy Technician’s Letter, Hospital Prescriber’s Letter, Pharmacist’s Letter Canada, Pharmacy Technician’s Letter Canada, Pharmacy Technicians University, NetCE, CriticalPoint, and Natural Medicines (collectively, the “Website”), has collected the following categories of personal information from its consumers within the last twelve (12) months:
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||YES|
|C. Protected classification characteristics under California or federal law.||YES|
|D. Commercial information.||NO|
|E. Biometric information.||NO|
|F. Internet or other similar network activity.||YES|
|G. Geolocation data.||NO|
|H. Sensory data.||NO|
|I. Professional or employment-related information.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||YES|
|K. Inferences drawn from other personal information.||YES|
Personal information under the CCPA does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information that is excluded from the CCPA's scope due to the applicability of other laws, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Therapeutic Research Center obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- From your employer, in cases where your subscription is provided by your employer
- Indirectly from you. For example, from observing your actions on our Website.
- From third-party business partners such as analytics providers.
Use of personal information
We may use, or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns. If you provide your personal information in order to track or complete continuing education or meet licensing or accreditation requirements, we will use your information to provide and report your continuing education credits or report completions of any applicable licensing or accreditation requirements.
- To provide, support, personalize, and develop our Website, products, and services.
- To detect and correct any errors in our Website, products and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests
- To prevent fraud and help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Therapeutic Research Center’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Therapeutic Research Center about our Website users is among the assets transferred.
Therapeutic Research Center 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.
Sharing personal information
Therapeutic Research Center may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, 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 share your personal information with the following categories of third parties:
- Service providers.
- Data analytics providers.
- Licensing authorities
- Accreditation authorities
Disclosure of personal information for a business purpose
In the preceding twelve (12) months, Therapeutic Research Center has disclosed the following categories of personal information for one or more of the business purposes described above in Use of Personal Information:
- [Category A: Identifiers.]
- [Category B: California Customer Records personal information categories.]
- [Category D: Commercial information.]
- [Category F: Internet or other similar network activity.]
- [Category K: Inferences drawn from other personal information.]
We disclose your personal information for a business purpose to the following categories of third parties:
- Continuing education accreditors or reporting entities.
Sales of personal information
In the preceding twelve (12) months, Therapeutic Research Center has not sold personal information.
Your rights and choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to specific information and data portability rights
You have the right to request that Therapeutic Research Center 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 (see Exercising Access, Data Portability, and Deletion Rights), 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 sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion request rights
You have the right to request that Therapeutic Research Center 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 (see Exercising Access, Data Portability, and Deletion Rights), 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, 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 (800) 995-8712.
- Webform request at: http://info.therapeuticresearch.com/privacyofficer
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. 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.
- 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.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
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.
Please note that once you have submitted a request, we will send you a receipt, acknowledging your request, within 10 days. If, for some reason, you do not receive such a receipt within 10 days of your submitted request, please send us an email to ContactUs@TRCHealthcare.com as an error may have occurred.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, 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 will not discriminate against you for exercising any of your CCPA rights. We will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California privacy
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. While we do not provide information to third parties for their direct marketing purposes, you may still make such a request, please complete a request at: http://info.therapeuticresearch.com/privacyofficer.
Changes to our privacy notice
Therapeutic Research Center reserves 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.
Phone: (800) 995-8712
Webform link: http://info.therapeuticresearch.com/privacyofficer
1720 S Bellaire St.
Denver, CO 80222