Our Website is designed to make it easy and convenient for enrollees in our prescription drug purchasing programs to order prescriptions and review information about prescription medications.  This privacy policy and agreement (the “Privacy Policy” or “Policy”) explains how, with your permission (as set out below) ECB Rx, LLC (“we” or “us”) collects, uses, and treats information that we receive about you in connection with our Rx 'n Go Program (the "Program").  The terms “you” and “your” refer to (1) an Enrollee in our Program, or other individual about whom we have information (each a “Data Subject”) and (2) an individual who provides to us information about a Data Subject.
For your convenience, Section 14 provides a full set of definitions used in this Privacy Policy

1. Your Consent
Please read this Privacy Policy carefully; when you consent to this Policy’s terms, it creates legal obligations on you and on us.  If you do not agree with the terms of this Privacy Policy, please refrain from using our Site, or enrolling in our Rx 'n Go Program.  We ask you to show your consent to the terms of this Privacy Policy in different ways, depending on your relationship to us.

1.1. Via the Website and Online Registration.  By accessing and using our Website as a Site Visitor, you agree to be bound by the terms of this Privacy Policy.  In addition, if you register as an Enrollee over the Website, you will be required to click an “I Accept” button linked to this Policy during the registration process.  By clicking "I accept," you further confirm your consent to the terms of this Privacy Policy

1.2. Via Telephone Registration.  If you register as an Enrollee by telephone through our Program Call Center, during the registration process our customer service representative will inform you of this Policy, and either provide you with the internet address for the Policy, or provide you with another method to obtain the Policy (or a Policy summary).  We will treat your decision to continue to participate in our Rx 'n Go Program, after being informed of our Privacy Policy, as your consent to this Privacy Policy.  If you later wish to withhold your consent to the terms of this Privacy Policy, you remain free to withdraw from our Rx 'n Go Program, and remove your name from our records, in accordance with Section 9 (Access; Removing Information).

1.3. Via Mail Registration.  If you wish, you may also register as an Enrollee through the mail.  To register in this manner, you will complete certain forms providing us with Enrollment information.  With these materials, we will inform you of our Privacy Policy and will either (i) provide you with a copy of this Policy (or a Policy summary), or (ii) provide you with directions on how to obtain a copy of this Policy (or our Policy summary).  We will treat your decision to continuing to participate in our Rx 'n Go Program, after being informed of our Privacy Policy, as your consent to this Privacy Policy.  If you later wish to withhold your consent to the terms of this Privacy Policy, you remain free to withdraw from our Rx 'n Go Program, and remove your name from our records, in accordance with Section 9 (Access; Removing Information).

1.4. Permission to Provide Information.  If you provide information to us about a Data Subject other than yourself, you confirm that you have first obtained permission from the Data Subject to provide the information, and that this permission is sufficient for the uses and practices set out in this Privacy Policy.

1.5. Confirmation.  For convenience, we make this Policy available on each page of our Website via a "Privacy" link and periodically provide you with a further copy of this "Privacy" link in our email communications with you. These communications are intended to ensure that you are well informed about our privacy and security practices, as set out in this Policy, and that we have your continued consent to the terms of this Policy.  If you no longer agree to the terms of this Policy, you may cease your involvement in the Program and remove your Personal Information from our databases, as set out in Section 9 (Access; Removing Information). 

2. The Types Of Information You May Provide
Relevant information under this Policy falls into five categories: (i) Contact Information; (ii) Medical Information; (iii) Payment Information; (iv) Anonymous Information; and (v) Community Comments.  These categories are defined, below:

2.1. Contact Information.  The term “Contact Information” means information that allows us (or others) to contact you, and this information consists of your name, mailing address, telephone number, email address, and other contact information.

2.2. Medical Information.   To properly process your Rx 'n Go orders for prescription drugs, your physician will need to provide a prescription on your behalf.  In addition, there will be times when you may be required to provide information about your health conditions, lifestyle, drug allergies, or other medications you may be taking.  The term "Medical Information" means this information:  specifically, information concerning prescriptions, your health conditions, private or sensitive information concerning your lifestyle, and information concerning drug allergies, or other medications you are taking.  The term "Medical Information" includes this Information compiled over time, in the form, for example, of a claims history.  Finally, the term "Medical Information" includes information (where applicable) that qualifies as "protected health information" under HIPAA Privacy Requirements. 

2.3. Payment Information.  The term “Payment Information” means credit card information, and other similar information you may provide to us in order to pay for prescription drug purchases (and other requested transactions) under our Rx 'n Go Program. 

2.4. Anonymous Information.  The term “Anonymous Information” means information that does not identify you, or any other Data Subject, and may include anonymous statistical information concerning, for example, the pages on our Website that Users visit most frequently, and the group and other preferences of our Users, in anonymous form. 

2.5. Community Comments.  The term “Community Comments” means information that a User voluntarily provides through bulletin board, blogging, networking, or other similar User-to-User communications services we may provide on the Website. 

2.6. Personal Information.  The term “Personal Information” means (i) Contact Information; (ii) Medical Information; and (iii) Payment Information.  The term "Personal Information" does not include Anonymous Information or Community Comments.

3. Program Service Providers
To facilitate efficient, secure, and HIPAA-compliant delivery of our Rx 'n Go Program to you, we have engaged, and rely on, two third-party service providers, independent of ECB Rx (our "Program Service Providers").  First, we have engaged a pharmacy benefit manager (the "Program PBM").  The Program PBM's responsibilities include processing and adjudicating pharmacy claims with respect to our Program.  Second, we have engaged a pharmacy (the "Program Pharmacy"), and the Program Pharmacy's responsibilities include communicating with your physician concerning your prescriptions and filling these prescriptions.  We have designed our relationship with our Program Service Providers in part to maintain compliance with HIPAA Privacy Requirements.  We have, accordingly, structured the collection and sharing of your Personal Information – and particularly your Medical Information – between ECB Rx and our Program Service Providers in a manner designed to keep your Personal Information private.  This Privacy Policy further describes this ECB Rx-Program Service Providers relationship, and the privacy and security practices that apply to our Rx 'n Go Program. 

4. Our Collection and Use Of Information
We use Personal Information only as specified in this Policy.  We collect information at different points in our Program, and use this information as described below:

4.1. Enrollment.  In order to access our Program services, we require that you complete a registration and become an Enrollee.  Our registration forms ask for Contact Information, which includes such items as your (i) name; (ii) mailing address; and (iii) email address, and other Personal Information.  We use the information you provide during the registration process to provide you with a user name and a password, and to allow you to gain access to password protected areas of the Site. We also pass your enrollment information to our Program Service Providers, to establish your Program account and allow the processing of your orders.  Under certain enrollment methods, such as enrolling by telephone, we may rely on our Program Service Providers (particularly our PBM) to collect the requisite information directly from you.  The Program Service Provider will then circulate the information as set out above, to activate your account. 

4.2. Fulfilling Your Orders.  We use Personal Information to process your orders, and have them fulfilled through our Rx 'n Go Program.

4.3. Prescriptions and Medical Information.  In order to fill your prescriptions, our Program Service Providers, and particularly the Program Pharmacy, will use requisite Medical Information.  For example, after you contact your physician for a prescription refill, your physician will communicate with the Program Pharmacy (either by phone, by fax, or otherwise) to transmit the prescription to the Pharmacy.  We at ECB Rx will not have access to this prescription information, or to any prescription information identified with you (though we will have access to Anonymous Information concerning prescriptions).  Our Program Service Providers will use your Medical Information in order to fill your orders, and (where applicable) provide information to you and your healthcare providers, as provided under our Rx 'n Go Program. 

4.4. Account Transactions and Preferences.  Our Program collects information about our Enrollees' transactions, including their transactions and other communications with our Program Service Providers.  We use this information in evaluating the types of prescription drug benefits, features, availability, and services that our Enrollees may find useful, in making business judgments concerning our relationship with you, and for other business and Program purposes, including for purposes of assessing the information with our Program Service Providers. 

4.5. Informational Notices and Bulletins.  Periodically, we may choose to send news, bulletins, or other information to Enrollees and other Users, and will use Contact Information to send such communications. If we choose to undertake such communications, you will have the ability to opt out of receiving these communications as provided in Section 8 (Opting Out), provided, however, that you cannot opt out of certain core Program-related communications.  Please refer to Section 8 (Opting Out) for more details.

4.6. Surveys.  Periodically, we may initiate surveys on our Site, through email or by other means, and we may request Contact Information or other Personal Information from you in connection with such surveys. You are free to choose whether you participate in this type of survey. Survey information will be used for purposes of monitoring or improving the use and appeal of our Site, improving our Program, or for other business purposes.  The information we receive through the survey will be used in accordance with this Privacy Policy and, if we want to use any Personal Information in a manner different than set forth in this Policy, we will notify you of relevant details in connection with asking for your participation in the survey. 

4.7. Requested Third-Party Information.  There may be occasions where we ask you to provide Contact Information (or other Personal Information) concerning a third party.  For example, we may ask you for the name and email address of the person who referred you to us, or for the name and address of a contact person, or for information in connection with a "Tell a Friend" program.  We will contact these individuals only for the specific purposes we have identified in connection with the request, and you will be free to choose whether or not to provide us with the information.  Moreover, rest assured that we will protect any third party's Personal Information that you provide in the same way we protect your Personal Information.  Before you submit Personal Information about third parties to us, please be sure you have permission from the third party to share this information with us.

4.8. Promotions.  We believe that our Users’ own experiences with us can often act as the strongest promotion for our Program.  To promote and illustrate our products and services, we may wish to post on our Website, or elsewhere, endorsements from our Users and other descriptions of our Users' experiences.  If we believe that others would benefit from your experiences in our Program, we will contact you, and ask for your consent before we share this information with other Users. 

4.9. Verifying Identity.  When you request a product, service or information, we may collect (and our Program Service Providers may similarly collect) additional Personal Information to verify your identity and process your request, beyond the data we originally received about you. This is designed to further protect you and to reduce the threat of identity theft and fraudulent orders. 

5. Anonymous Information
We use Anonymous Information to analyze the effectiveness of our Site, to improve our products and services, and for other similar purposes.  In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of Enrollees participating in our Program, the characteristics of Users at our Site, and other similar analyses.  We may share Anonymous Information with third parties, including advertisers (if any).  Rest assured, though, that Anonymous Information provided to third parties will not allow anyone to identify you or any other Data Subject, or to determine anything personal about you or another Data Subject.  We may collect Anonymous Information through features of the software that supports our services, through cookies, and through other means described below. 

5.1. IP Addresses; Logs.  Either directly, or through our hosting service provider, we may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your PC), your computer’s name, the type and version of your web browser, referrer addresses, where the computer is routing from, and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Website is being used, and for security and monitoring purposes.

5.2. Cookies.  A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Website and use them to recognize you when you return to our Website.  You may set your browser so that it does not accept cookies.  Cookies must be enabled on your web browser, however, if you wish to access certain personalized features of our services.

5.3. Tags.  We may use so-called “pixel tags” — small graphic images (also know as “web beacons”, “single-pixel GIFS”, or “Web bugs”) — for purposes such as (i) to tell us what parts of our Website have been visited, (ii) in connection with advertisements we may include on the Site, (iii) to measure the effectiveness of searches you perform on our Site, and (iv) for other purposes. Pixel tags also enable us to send email messages in a format you can read, and they inform us whether emails have been opened, to help ensure that our messages are of interest to our Users and others. None of this data includes Personal Information, and you can “opt-out” of receiving these types of emails from us by following the directions provided in Section 8 (Opting Out).  If any Personal Information is collected using such tools, it will be subject to the terms of this Privacy Policy.

5.4. Click-Throughs.  We may send email messages which use a “click-through URL” linked to content on our Website. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked simply do not click text or graphic links in the email, or notify us in accordance with Section 8 (Opting Out).

5.5. Banner Ads; Advertising Profiles.  Our Site may include the use of ad banner partners for the serving and/or targeting of ads, promotions, and other marketing messages. These ads may be provided, in some cases, by a third party ad service provider or advertiser (“Advertisers”). These Advertisers may use traditional banner ads, or other advertising methods, such as advertising using profiles and related content.  An Advertiser may place or utilize its own cookie on your browser, and may use Anonymous Information about your visit to our Site, such as the number of times you have viewed the ad. If the Advertiser requests that you provide to it Personal Information, please be aware that this Advertiser’s use and collection of this information will be governed by its own privacy policy, and not our Policy.  We recommend that you review the Advertiser’s privacy policy before providing Personal Information. 

6. Any Information Linked With Personal Information Is Protected As “Personal Information”
To enable us to better understand your characteristics and/or to provide services tailored to our Users, we may link Personal Information with Anonymous Information. If we combine or link any Anonymous Information with your Personal Information, the resulting combination will be treated and protected as Personal Information under this Privacy Policy

7. Disclosures To Third Parties
We do not disclose your Personal Information to any third-party person or entity other than those persons and entitled listed below.  If we wish to disclose your Personal Information to anyone else, we will not do so without your express consent. 

7.1. Program Service Providers.  Our Program Services Providers will obtain Personal Information directly from you and (where applicable) your healthcare providers.  In addition, we will share your Personal Information with our Program Service Providers to fulfill your orders and Program requests, and for other purposes identified in this Privacy Policy

7.2. Vendors.  We employ certain companies to perform other functions on our behalf, such as hosting and maintaining the Website, providing services related to our products, responding to and sending electronic mail, or other functions necessary to our Rx 'n Go Program (collectively, “Vendors”).  We share Personal Information with our Vendors, to permit them to perform their functions in our Program. We provide our Vendors with only that Personal Information necessary to perform these functions.  In addition, we require that our Vendors agree contractually to comply with privacy laws, and agree to maintain protections for Personal Information that are consistent with this Policy.

7.3. Our Employees.  We share Personal Information with our employees, to allow them to provide Program services to you, and to otherwise perform their duties.  Our employees are obligated to maintain protections for your Personal Information that are consistent with this Policy

7.4. Questions of Harm.  We may reveal Personal Information about Data Subjects, on a case-by-case basis, to attorneys, private investigator organizations, or law enforcement agencies if we believe (a) that the Data Subject is at risk of harm, or (b) that the Data Subject is harming or interfering (or will harm or interfere) with others, is violating (either intentionally or unintentionally) our Website Terms of Use, or is otherwise violating legal obligations.

7.5. Legal.  We will reveal Personal Information about a Data Subject to the extent we reasonably believe we are required to do so by law. If we receive legal process calling for the disclosure of Personal Information about a Data Subject, we will attempt to notify the Data Subject via the email address we have on file for the Data Subject within a reasonable amount of time before we respond to the request, unless such notification is not permitted.

7.6. Transfer of Ownership.  We shall be entitled to transfer Personal Information to a third party in connection with a sale of all or substantially all of the assets of the business entity responsible for the information under this Policy, provided the acquiring third party has agreed to safeguard your Personal Information with protections that in material respects are the same as, or more protective than, those set out in this Privacy Policy.

8. Opting Out
If we choose to send bulletins, updates, product offerings, or other communications to you, we will provide you with the ability to decline – or “opt-out of” – receiving such communications.  Instructions for opting-out will be provided if and when we determine to send such a communication.  Please understand that you will not be allowed to “opt–out” of formal notices concerning operation of our Websites, and legal and other related notices concerning your relationship to us or the Website. 

9. Access; Removing Information
We provide you with online access rights to your Personal Information and provide you with the right, upon request, to remove your Information from our databases.  Please understand, however, that it may be impossible to remove this information completely, due to backups and records of deletions.  In addition, please understand that, if you request deletion of your information, you will be unable to participate further in our Rx 'n Go Program.  You may not remove de-identified, anonymous, or aggregate data from our databases. 

10. Your Responsibility For Community Comments
We may choose to implement bulletin board, blogging, networking, or other similar User-to-User communications services on our Website.  If you decide to participate in these services and provide Community Comments via these services, we counsel you to take care when providing these Comments.  Our Privacy Policy does not cover your Community Comments.  Accordingly, you "act at your own risk" if you choose to provide sensitive information in your Community Comments.  Before posting a Community Comment, please consider whether the Comment contains information the Data Subject would prefer to keep private, and refrain from disclosing such information.

11. Security
We have put in place security systems, physical safeguards, technical safeguards, and quality controls designed to prevent unauthorized access to, or disclosure of Personal Information.  Our security systems are structured to deter and prevent unauthorized users and others from accessing Information we receive about Data Subjects.  Please understand, though, that these safeguards are not fail-proof and, due to the nature of Internet communications and evolving technologies, we cannot provide, and disclaim (to the extent permitted by law), assurance that the information we receive about Data Subjects will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
Moreover, please keep in mind that you also play a key role in protecting the security of information about you. For example, you should guard your password to our Website, and decline to allow others to use this password.  In addition, you should close your browser when have finished viewing your information on our Website, to prevent others from viewing your Personal Information.

12. Website Participation By Children and Teens; Advisory
Due to federal law (as reflected in the Children’s Online Privacy Protection Act), WE DO NOT ALLOW INDIVIDUALS WHO WE KNOW ARE UNDER 13 TO PARTICIPATE IN OUR WEBSITE OR SERVICES.  YOU MUST BE AT LEAST 13 YEARS OLD TO USE OUR WEBSITE AND SERVICES. IF YOU ARE BETWEEN 13 AND THE APPLICABLE AGE OF MAJORITY, PLEASE REVIEW THIS AGREEMENT WITH YOUR PARENT OR GUARDIAN.  Please understand that we cannot necessarily tell if a user is providing us with his or her true age. 

13. Notification Of Changes
From time to time, we may change our Privacy Policy. If we make any changes regarding the Policy, we will post the new Policy via the privacy link on our Website and make the new Policy available in paper-form upon request.  Changes to the Privacy Policy will become effective upon your consent to these terms, pursuant to Section 1 (Your Consent) and will be retroactive to the first time we received Personal Information from or about you.

14. Definitions

14.1. Anonymous Information.  The term “Anonymous Information” has the meaning set forth in Section 2.4. 

14.2. Contact Information.  The term “Contact Information” has the meaning set forth in Section 2.1.

14.3. Enrollee. The term “Enrollee” means an individual who is duly enrolled in, and entitled to receive services through, the Program. 

14.4. HIPAA Privacy Requirements.  The term "HIPAA Privacy Requirements" means applicable provisions of the Administrative Simplification section of the Health Insurance Portability and Accountability Act of 1996, and any regulations promulgated thereunder, including without limitation the federal privacy regulations (45 CFR Part 164) and the federal security standards (45 CFR Part 142).

14.5. Medical Information.  The term "Medical Information" has the meaning set out in Section 2.2 (Medical Information). 

14.6. PBM.  The term "PBM" has the meaning set out in Section 3 (Program Service Providers). 

14.7. Personal Information.  The term “Personal Information” has the meaning set forth in Section 2.6 (Personal Information).

14.8. Pharmacy.  The term "Pharmacy" has the meaning set out in Section 3 (Program Service Providers). 

14.9. Program Service Providers.  The term "Program Service Providers" has the meaning set out in Section 3 (Program Service Providers). 

14.10. Program.  The term "Program" means our Rx 'n Go prescription drug program. 

14.11. Site Visitor.  The term “Site Visitor” means any individual who visits our Website.

14.12. User.  The term “User” means (i) Site Visitors, (ii) Enrollees, and (iii) others who provide information (including Personal Information) in connection with our Program. 

14.13. Website.  The term "Website" means the Website for the Program, located at rxngo.com. 

15. Contact Us
If you have any questions about this Privacy Policy, the practices of this Site, or our Rx 'n Go Program, please contact us at: 

ECB Rx, LLC
53 W Ogden AVenue
Clarendon Hills, IL 60514
email at: information@ecbrx.com

16. Effective Date
The effective date of this Privacy Policy along with any updates here to is April 10, 2009 
COPYRIGHT AND LEGAL NOTICE.
© 2010 - 2014 ECB Rx, LLC. All rights reserved. Rx ‘n Go is trademark of ECB Rx, LLC.


Table (for convenience)
1. Your Consent
2. The Types Of Information You May Provide
3. Program Service Providers
4. Our Collection and Use Of Information
5. Anonymous Information
6. Any Information Linked With Personal Information Is Protected As “Personal Information”
7. Disclosures To Third Parties
8. Opting Out
9. Access; Removing Information
10. Your Responsibility For Community Comments
11. Security
12. Website Participation by Children and Teens; Advisory
13. Notification of Changes
14. Definitions
15. Contact Us
16. Effective Date