Privacy Policy
Summary of Changes
• Added “Deleting Your Data” to clarify that we will delete your account and personal information we have if you ask us to.
• Added “Data Retention,” which explains that we will keep your data stored and secure as long as you have an account with us.
• Added “Acceptance of and Changes to Privacy Policy,” which explains that we will notify you in the Huddle application when there are material changes to the Privacy Policy.
DrFirst will not sell your data. DrFirst.com, Inc. (“DrFirst”) is committed to safeguarding your privacy. This policy (“Privacy Policy”) explains what information we gather, use, and share when you use the Huddle application. By using Huddle you agree to be bound by the terms of this privacy policy and the Terms of Use.
Information We Collect
We may collect Personal or Non-Personal Information from you or about third parties for whom you provide information to the Huddle application. “Personal Information” refers to any information that specifically identifies you as an individual that you provide in connection with your use of our Site. Personal Information may include but is not limited to your name, telephone number, email address, postal address, and location. Personal Information may also include prescription information or other medical information. “Non-Personal Information” is any information you provide to us that cannot be used to determine your identity. The types and amount of information collected for the features listed above will vary depending on your use of the Huddle application. The requested Personal Information may include: first and last name, email address, and telephone number. For some activities, you may be asked to create a username and/or password and/or to provide additional, demographic information, including your age, date of birth and/or gender.
How We Collect Information About You
We only obtain Personal Information that you provide to us, such as when you request information from DrFirst, or transfer information from other applications or stored on a device. By using Huddle and submitting Personal Information, you consent to the collection and use of your Personal Information by us as described in this Privacy Policy. In addition, when you access or visit Huddle, we and our service providers and others who host Huddle may use technology that can recognize, collect, and transmit information that is associated with you, but which does not personally identify you.
How We Use Information Collected
To the extent permitted by applicable law, we use information collected or obtained when you use Huddle, including Personal Information for the purposes set out below: Market research; Creating new features and services; Development of services, new and updated products; Responding to feedback, questions, and communications concerning our products or services; Informing you about our services which may include contacting you by telephone (including by SMS text); and Maintenance and administration of Huddle.
Deleting Your Data
You have the right to request that we delete Personal Information we collect or obtain about you, subject to certain restrictions. Should you choose to delete your account, please contact us at https://sdesk.drfirst.com/support and we will contact you. Medication information you share with your provider is retained in accordance with the Health Insurance Portability and Accountability Act (HIPAA) requirements.
Data Retention
We retain your Personal Information for as long as you have an open account with us or as otherwise necessary to improve Huddle for all users generally. In some cases, we retain Personal Information for longer, if necessary, to comply with our legal obligations, resolve disputes, or is otherwise permitted or required by applicable law or regulations.
IP Addresses
We may keep track of Internet Protocol (IP) addresses to (among other things): (i) troubleshoot technical concerns, (ii) maintain website safety and security, (iii) restrict access to our Site to certain users, and, (iv) to better understand how Huddle is utilized. An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.
Log Files
We (or a vendor on our behalf) may collect information in the form of logs – files that record activity and gather statistics about users’ habits in the Huddle application. These entries help us gather (among other things) (i) a user’s browser type and operating system, (ii) information about a user’s session (such as the URL they came from, the date and time they visited the application, and which pages they’ve viewed on our site and for how long), and, (iii) other similar navigational or click-stream data. We also use information captured in log file for our internal marketing and demographic studies, so we can constantly improve and customize the online services we provide you.
Business Interests
We may combine (aggregate) your Non-Personal information with other consumers’ information or other publicly available information to help us satisfy our legitimate business interests, such as performing trend analysis or market studies; identify consumer preferences or interests; set prices; perform billing functions; establish credit; or comply with government regulations. We may also share anonymized data, such as statistical or demographic information in aggregate form, with third parties for research or marketing purposes. However, this anonymized data will not contain your individually identifiable Personal Information.
Disclosure of Information to Third Parties
We will disclose your Personal Information to third parties you designate in your use of the Huddle application. Any disclosures that we make will be in accordance with the Terms of Services. We disclose your Personal Information to our service providers that we engage to provide certain services, such as hosting and maintenance, data storage, customer management and disaster recovery. We expect our service providers to use reasonable measures in order to protect your privacy and Personal Information from unauthorized access, in accordance with our agreements with them and applicable law. To the extent permitted by our agreements and applicable law, we also reserve the right to make your Personal Information available: to third party marketing and advertising companies; to comply with any applicable law, regulation, a court or other legal process, or enforceable government request; to take appropriate action regarding any use of our application that may violate any law or regulation; to protect the health, safety, security, property, and interests or rights of us or others; to investigate or respond to or resolve problems or inquiries or defend our interests; and as otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law; and as directed by You.
California privacy rights. If you are a resident of the State of California, under the California Consumer Privacy Act of 2018 (CCPA), you have the following rights with respect to your information collected by companies conducting business in California:
Right to Access Personal Information We Collect. You have the right to request a copy of Personal Information we collect about you, subject to certain restrictions.
Right to Access Personal Information We Sell or Disclose to Third Parties. You have the right to request a copy of your Personal Information we sell or disclose to third parties, subject to certain restrictions.
Right to Request Deletion of Personal Information We Collect. You have the right to request that we delete Personal Information we collect about you, subject to certain restrictions.
Right to Be Free from Discrimination. You have the right to be free from discrimination for exercising your rights under the CCPA.
Personal Information We Collect About You. Under the CCPA, Personal Information refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. Below is a list of categories of Personal Information we collect about you:
Identity Information such as first name, last name, driver’s license or state identification, passport number, or similar identifier.
Contact Information such as physical addresses, e-mail addresses, and phone numbers.
Education and Employment Information such as schools and colleges/universities attended, degrees earned, certifications and licenses, and other professional-related data.
Technical and Usage Information such as login data, Internet Protocol (IP) address, geolocation data, access dates and times, cookie data, browser activity, and other user interactions with our websites, applications, and platforms.
Marketing Information such as your preferences in receiving marketing materials and communications from us.
Profile Information such as your usernames and passwords, feedback, and survey responses.
Transaction Information such as details regarding products and services purchased from us.
Financial Information such as payment details, either directly collected by us or indirectly collected through a third party payment service provider.
Medical Information that is not governed under the Health Information Portability and Accountability Act (HIPAA) or the Confidentiality of Medication Information Act Part 2.6.
We also collect information that is not considered Personal Information under the CCPA. This includes publicly available information such as information lawfully made available from federal, state, or local government records. Protected or health information collected that is governed by HIPAA or the Confidentiality of Medical Information Act is not subject to the CCPA.
Personal Information We Share with Third Parties. We disclose your Personal Information to third parties for business purposes. We require all third parties to respect the security of your Personal Information and to treat it in accordance with applicable law. Below is a list of categories of Personal Information we may share with third parties:
Identity Information such as first name, last name, driver’s license or state identification, passport number, or similar identifier.
Contact Information such as physical addresses, e-mail addresses, and phone numbers.
Education and Employment Information such as schools and colleges/universities attended, degrees earned, certifications and licenses, and other professional-related data.
Marketing Information such as your preferences in receiving marketing materials and communications from us.
Profile Information such as your usernames and passwords, feedback, and survey responses.
Transaction Information such as details regarding products and services purchased from us.
Medical Information that is not governed under the Health Information Portability and Accountability Act (HIPAA) or Confidentiality of Medication Information Act Part 2.6.
Personal Information We Sell to Third Parties. We do not sell your Personal Information to third parties.
To more information, contact us via one of the following:
Toll-free telephone at 1-866-263-6512
JIRA Service Desk at https://sdesk.drfirst.com/support
Postal mail, at:
DrFirst.com, Inc.
9420 Key West Ave, Suite 101
Rockville, MD 20850
Attn: Legal Department –
California Privacy Rights
All requests sent via postal mail must be labeled “California Privacy Rights” on the envelope or post card and clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. We will respond to your request within forty-five (45) days, or within a timeframe otherwise permitted under the CCPA. You will not be required to pay a fee to access to your Personal Information. However, we may charge a reasonable fee if your request is unfounded, excessive, or repetitive.
How We Respond to Browser “Do Not Track” Signals
Some web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. How browsers communicate the Do Not Track signal is not uniform. For this reason, Huddle is not set up to interpret or respond to Do Not Track signals.
Children’s Online Privacy Protection Act (COPPA)
Neither Huddle nor any services available through Huddle are directed to children under the age of 13. We do not knowingly collect Personal Information directly from children and will destroy such information if we become aware that a child has disclosed such information to us without proper parental consent. It is DrFirst’s policy not to knowingly solicit or permit children under the age of 13 to provide their Personal Information for any purpose.
Acceptance of and Changes to Privacy Policy
By using Huddle, you are accepting the practices described in this Privacy Policy. Although most changes are likely to be minor, we may modify this Privacy Policy from time to time. Any modified privacy policy will be posted in the Huddle application and be marked with an effective date. We will notify you of material changes to this Privacy Policy. Your consent and/or continued use of Huddle after the effective date of any modification means you accept and agree to be bound by the Privacy Policy as modified. Any material changes will generally apply only to activities and information collected after modification. We encourage you to review this Privacy Policy whenever you return to Huddle to make sure you are aware of the latest Privacy Policy.
Third Party Websites
Huddle may contain links to and from websites maintained by other companies or organizations (“Third Party Websites”). We are not responsible for the privacy practices or the content of Third Party Websites. The information practices of Third Party Websites are not covered by this Privacy Policy.
Note to Non-U.S. Visitors
This Privacy Policy is intended to meet the laws and regulations of the United States, which may not necessarily be consistent with the laws and regulations of your home country. Any information that you provide to www.drfirst.com will be treated in accordance with this Privacy Policy, the Terms of Use, and U.S. laws. Huddle is not intended for use outside of the United States of America. Huddle is expressly not intended for use in the European Union or by any individual inside or resident of a European Union member state or any jurisdiction subject to the laws of the European Union.
Revision Date: 10/29/2020
