PLEASE REVIEW THIS PRIVACY AND SECURITY POLICY CAREFULLY. It describes how we collect, use, and disclose information that we obtain about visitors of our Site and users of our Services. This Privacy and Security Policy is incorporated into our general Terms of Service, which can be accessed here.
Freshman does not provide medical advice nor does it dispense any prescriptions. By visiting the Site or using our Services, you acknowledge and agree that your Personal Information will be handled as described in this Policy.
We reserve the right, at our discretion, to change, modify, add, or remove portions of this Policy at any time. Material changes will be conspicuously posted on the Site or otherwise communicated to you. All changes will be effective immediately upon posting to the Site.
INFORMATION COLLECTION & USE
We collect personal information and sensitive personal information using three primary sources: 1) from you; 2) using automated technology through our Services such as when you visit our Site or communicate with us including through email; and 3) through third-party sources including service providers, data brokers, social networks, advertising companies, business partners, governmental entities, public records, and internet service providers. Automated technology collects information from your computer or mobile device and includes cookies, web beacons, local shared objects, or other similar tracking technology.
All personal information and sensitive personal information will be used as stated in this Policy. We may combine data collected from third party sources.
We collect personal information such as your name, email address, mailing address, and telephone number, when you use our Services. We collect sensitive personal information relating to your account.
We collect data about you automatically through your browser, device, hardware, and software. This information includes your IP address, device ID, browser type, domain names, access times and dates, number of clicks, pages viewed, one or more cookies (as described below) that may uniquely identify your browser and referring website addresses through our Services. We or other parties may collect personal information and sensitive personal information about your online activities over time and across different websites when you use the Site.
We collect precise geolocation and records of products or services purchased, obtained, or considered.
We use your personal information for the following purposes:
- Provide you with our products and Services or information you request including performing a contract we’ve entered with you, processing orders or fulfilling other transactions;
- Respond to your questions and queries including to provide support and assistance to you;
- Track traffic patterns and analyze your Site usage so we can understand how you use our Site and make your experience better;
- Enhance, modify, and improve our products, Services, business, and Site;
- Address information security and/or privacy issues, network functioning, and troubleshooting;
- Investigate claims and/or legal actions, violations of our policies and procedures, and compliance with relevant appliable laws and legal process;
- Comply with applicable laws, regulations, or legal process as well as industry standards and our company policies;
- Research, testing and product development, marketing and other business purposes including for analytics and profiling technology to customize your experience, deliver content tailored to your preferences, to market to you through targeted advertising;
- Send promotional communications or offers to you;
- As otherwise specified at the point of collection.
HOW WE SHARE YOUR INFORMATION
We share your personal information and sensative personal information with:
- Service Providers. We share your information with service providers who have agreed to keep the information confidential and use it only to provide the applicable service(s) that we use to support our business and operations such as vendors that host our Site and data and fraud detection companies.
- Third-Party Vendors. We share your information with third party vendors that we work with to gather information about you, communicate with you, and advertise to you including entities that sponsor sweepstakes/contests, social media companies, companies that provide data analytics and targeted advertising services.
- As legally Necessary. We share your information with third-parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations.
- In the Event of Merger, Sale, or Other Asset Transfers. We may share information with an acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation joint venture, assignment, transfer, or other disposition of all or any part of Freshman or its affiliates including any negotiation thereof.
- With Your Consent. We may share information with your consent and at your direction.
COOKIES & OTHER AUTOMATED TECHNOLOGY
A “cookie” is a small text file that is placed onto an Internet user’s web browser or device and is used to remember and/or obtain information about the user. A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity. They are also sometimes referred to as pixels and tags.
We and/or third parties may collect information using cookies, web beacons, pixels, and other similar technology, through the Services, for the purposes described in this Policy including to keep track of your interactions on our Site and other websites, to provide you with a more customized experience, and to serve targeted advertisements to you.
To find more information about cookies please visit www.allaboutcookies.org. Most browsers are initially set to allow cookies but also offer the option to restrict cookies or warn you of their use. By disabling cookies, you won’t be able to enjoy the convenience provided by our customization.
YOUR OPT-OUT OPTIONS
You may opt out as follows:
Setting your browser to restrict or decline cookies. Please refer to the “help” section in your browser. You may also adjust your privacy and advertising settings on your mobile device.
We may use Facebook products to advertise to you. To learn more about how Facebook uses your data, please visit: https://www.facebook.com/policy.php. To understand more about Facebook advertising and manage your preferences, please visit: https://www.facebook.com/about/ads.
We may use Tik Tok to advertise to you. To learn more about how Tik Tok uses your data, please visit: https://www.tiktok.com/legal/privacy-policy-us?lang=en. To understand more about Tik Tok advertising and manage your preferences regarding advertising, please visit: https://support.tiktok.com/en/account-and-privacy/personalized-ads-and-data/personalization-and-data?lang=en.
You can also opt out from companies like Google and other participating companies through the Network Advertising Initiative (NAI) NAI Website: https://optout.networkadvertising.org/?c=1 and the Digital Advertising Alliance in the USA: http://www.aboutads.info/choices/ or using your mobile device settings.
You may opt-out of receiving emails and communications from us any time by clicking on the Unsubscribe link provided in the footer of emails or by emailing us at firstname.lastname@example.org. Please note, even if you opt out of promotional communications, we will continue to send to you non-promotional emails such as service notices related to your account, billing, transactions and orders.
We maintain appropriate administrative, technical, and physical safeguards to protect your personal information and sensitive personal information, whether in transmission or storage. Please keep in mind, however, that there is no such thing as perfect security, and no Internet transmission is ever completely secure or error-free therefore we cannot guarantee the security of your personal information and sensitive personal information.
RETENTION OF DATA
We will retain your personal information and sensitive personal information for as long as it is necessary for the purposes described in this Policy. We will also retain and use your personal information and sensitive personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
ACCESS FROM OUTSIDE THE UNITED STATES
If you access the Site from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by other jurisdictions.
MINORS UNDER THE AGE OF 18
The Site and Services are not intended for minors under 18 years of age, and we do not knowingly collect Personal Information from minors under 18. If we learn we have collected or received Personal Information from a minor who is a child under age 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a minor under 18, please contact us at the contact information listed below.
PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS
The California Consumer Privacy Act (“CCPA”) requires us to provide California residents additional disclosures as set forth below. Terms used below have the meanings given them under California law as applicable.
Personal Information collected in the last 12 months
Information on the specific data points that we have collected is set forth above in the section “Information We Collect About You”. These data points correspond to the following categories of Personal Information that we have collected in the last 12 months as follows:
- identifiers (such as name, address, email address);
- personal information described in Cal. Civ. Code Section 1798.80
- characteristics of legally protected classifications under federal or California law;
- commercial information (such as transaction data);
- internet or other network or device activity (such as IP address);
- general geolocation information;
- visual information (such as your picture on your driver’s license);
- “Sensitive Personal Information,” such as your driver’s license, financial account and payment information, and medical information including information regarding your sex life.
Purposes of Collecting Personal Information
We collect the above categories of Personal Information for the purposes set forth in the section above titled “How We May Use Your Information”.
Sources of Personal Information
We collect the categories of Personal Information from those sources set forth in the section above titled “Information We Collect About You”.
We may retain your Personal Information, including Sensitive Personal Information, for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you;
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions or communications for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
Categories of Third Parties to Whom Personal Information is Disclosed
In the last 12 months, all of the above categories of Personal Information were disclosed to the categories of third parties set forth in the section above titled “How We Share Your Information” for the applicable business purposes set forth above in the section titled “Information Collection & Use”.
Sale or Sharing of Personal Information
We do not sell Personal Information for monetary compensation, however, under California law, sharing certain data to certain third parties online marketing and behavioral advertising may be considered the “sale” or “sharing” of your Personal Information. In the past 12 months, as contemplated by California law, we have sold or shared the following categories of information for purposes of online behavioral advertising to third party ad networks: identifiers and internet and other electronic network activity.
We do not have any actual knowledge that we have sold or shared Personal Information of any consumer under the age of 16.
Sensitive Personal Information
We do not use Sensitive Personal Information for any purpose other than that reasonably anticipated to accomplish the purpose for which it is collected.
Your California Privacy Rights
If you are a California resident, the CCPA allows you to make certain requests about your Personal Information. Specifically, the CCPA allows you to make the types of requests below at no charge:
Request to Delete
The right to request deletion of certain Personal Information we have collected.
Request to Access
The right to request access to and, subject to certain exemptions, receive a copy of the specific pieces of Personal Information that we have collected and to have this delivered, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, in a readily usable format.
Right to Know
The right to request information about the Personal Information we have collected about you, including:
- Categories of Personal Information collected;
- Categories of sources of Personal Information;
- Business and/or commercial purposes for collecting, selling, or sharing Personal Information;
- Categories of third parties with whom we have disclosed or shared Personal Information;
- Categories of Personal Information that we have disclosed or shared with a third party for a business purpose; and
- Categories of third parties to whom their Personal Information has been sold and the specific categories of Personal Information sold to each category of third party.
Right to Correction
The right to request that we correct inaccurate Personal Information.
Right to Opt Out of the Sale or Sharing of Personal Information
The right to opt-out of our sale or sharing of your Personal Information for online behavioral advertising.
Right to No Discrimination or Retaliation
You also have the right to not receive discriminatory treatment or retaliation if you elect to exercise the above rights.
Submitting a Request to Delete, Access, Know, or Correct
If you are a California resident and you would like to make a request to delete, access, know, or correct your Personal Information under California law, email us at email@example.com. Please include your full name, email address and address associated with your use of our Services, along with an identification of the rights you would like to exercise, so that we can process your request in an efficient manner.
Who May Exercise Your Rights
You may request the above on behalf of yourself or on behalf of a minor if you are the parent or legal guardian of the minor. In addition, you may authorize an agent to exercise your rights on your behalf, if you provide the agent with written signed permission.
Verification of Your Request
Once we receive your request, we will contact you to confirm receipt of your request. We will require sufficient information from you in order to verify your identity and the authenticity of your request. If you do not provide us with sufficient information in your request, we may request additional information to verify identity and the authenticity of the request. Certain types of requests may require additional verification, as we are subject to higher standards of authentication for certain requests.
If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent to act on your behalf, unless the agent holds a lawful Power of Attorney under applicable laws, in which case we will require evidence of such Power of Attorney.
We may deny your request as permitted or as required by law and we may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.
Submitting a Request to Opt-Out of the Sale or Sharing
You have the right to limit uses and disclosures of Personal Information and may request to opt out of the sale or sharing of your Personal Information for online behavioral advertising by emailing us at firstname.lastname@example.org.
Shine the Light Disclosure: Your Privacy Rights Regarding Third Party Marketing.
The California “Shine the Light” law, California Civil Code 1798.83, gives our California resident customers the right under certain circumstances to request information from us regarding the categories of Personal Information (as defined in the Shine the Light law) that we disclose to third parties or affiliates for their direct marketing purposes. To request such disclosure, contact us at email@example.com and identify your request as “Shine the Light”.
If you have any questions about this Privacy Information for California Residents section, please contact us at firstname.lastname@example.org.
PRIVACY INFORMATION FOR NEVADA RESIDENTS
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to email@example.com.
PRIVACY INFORMATION FOR VIRGINIA RESIDENTS
If you are a Virginia resident, Virginia law requires us to provide you additional disclosures. Terms used in this Virginia Notice have the meaning given to those terms in such laws and regulations.
Categories of Personal Information that we collect
We collect the categories of information as set forth above in the section “Information We Collect About You”.
Purposes of Collecting Personal Information
We collect the above categories of Personal Information for the purposes set forth in the section above titled “Information Collection & Use”.
Categories of Third Parties to Whom Personal Information is Disclosed
We disclose all categories of Personal Information to the categories of third parties set forth in the section above titled “How We Share Your Information.”
Your Virginia Rights
As a Virginia resident, you have the following rights regarding the Personal Information we collect about you:
Right to Request Access
You have the right to request confirmation whether or not we are processing your Personal Information and to access such Personal Information.
Right to Data Portability
You have a right to obtain a copy of your Personal Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means.
Right to Request Correction
You have a right to request to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of such Personal Information.
Right to Request Deletion
You have a right to request deletion of Personal Information provided by or obtained about you.
Right to Opt-Out
We do not sell Personal Information for money. However, you have a right to opt-out of the processing of the Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects on you.
Submitting a Request
You can exercise the foregoing rights by e-mailing us at firstname.lastname@example.org. If we are unable to authenticate the request using commercially reasonable efforts, we will not be required to comply with your request to initiate an action of your rights and may request that you provide additional information reasonably necessary to authenticate your request
If we reject or deny your request, you have the right to appeal our decision by submitting an appeal to email@example.com. This appeal request must be submitted within a reasonable time following our rejection of your request.
For questions about this Policy, email us at firstname.lastname@example.org.
CHANGES TO THIS POLICY
We may change this Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Policy. Your continued use of this Site after any such updates constitutes your agreement to this Policy and any future revisions.