Last updated:  October 31, 2024

Under the California Consumer Privacy Act (“CCPA”), California Consumers are entitled to certain notices and disclosures regarding the collection and use of their Personal Data. Specifically, California residents are entitled to receive pre-collection notice of: (1) the categories of Personal Data collected, including sensitive Personal Data; (2) the purposes for which the Personal Data is collected or used; (3) whether the Personal Data is sold or shared; (4) the length of time the business intends to retain each category of Personal Data; (5) if the business sells or shares Personal Data, the link to the Notice of Right to Opt-out of Sale/Sharing; and (6) the link to the business privacy policy.

This CCPA Notice at Collection (“Notice”) describes how Docupdate, an ImpiricusHealth Corp. (“Impiricus”) service, collects, uses, and shares Personal Data when you visit our website at http://docupdate.io, use our Prescriber mobile application or other mobile applications, or sign up for and utilize information provided by Us through text messages (collectively, our “Service”). For more information, please see our Privacy Policy.

For the purposes of this Notice:

• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Impiricus, 1 Concourse Parkway, Ste 800, 30328, GA, USA.
• Consumer means a natural person who is a California resident.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Categories of Personal Data Collected We collect 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 or Device. The following is a list of categories of Personal Data which we may collect or may have been collected from California residents within the last twelve (12) months:

• Category A: Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

We do not collect any Personal Data defined as “Sensitive Personal Data” under CCPA.

Sources of Personal Data We obtain the categories of Personal Data listed above from the following categories of sources:

• Directly from You. For example, from the forms You complete on our Service, preferences You express or provide throughout Service.

• Indirectly from you. For example, from observing Your activity on our Service.
• Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate throughout Service.
• From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, or other third-party vendors that We use to provide the Service to You.

Use of Personal Data for Business Purposes or Commercial Purposes.

We may use or disclose Personal Data We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

• To operate our Service and provide You with our Service.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, we will use that Personal Data to respond to Your inquiry.
• 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 Data
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
• For Messaging: When you submit your information using the form available at https://portal.docupdate.io/, your data will be used to deliver pharmaceutical messaging to you. This messaging may be sponsored by a pharmaceutical manufacturer. You have the right to opt out of any specific manufacturer's messaging by replying “No” or “Stop” as well as a right to request to opt out of all messaging as a whole by replying “No All”. You may also modify your messaging preferences by visiting https://www.docupdate.io/manage-preferences.
• We may disclose Your Personal Data for any other purpose with Your consent.

Please note that the examples provided above are illustrative and not intended to be exhaustive. If We decide to collect additional categories of Personal Data or use the Personal Data We collected for materially different, unrelated, or incompatible purposes We will update this Notice.

Disclosure of Personal Data for Business Purposes or Commercial Purposes

In the past twelve (12) months, we have not disclosed Personal Data for a business or commercial purpose.

Sale of Personal Data

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Data by the business to a third party for valuable consideration. In the last twelve (12) months, we have not sold Personal Data.

Sharing of Personal Data

As defined in CCPA, “sharing”  means disclosing a Consumer’s Personal Data to a third party for cross-context behavioral advertising. We do not “share” Personal Data as defined in CCPA.

We may disclose Your Personal Data identified in the above categories with the following categories of third parties:

• Service Providers
• Our affiliates
• Our business partners
• Third party vendors to whom You or Your agents authorize Us to disclose Your Personal Data in connection with products or services We provide to You

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set forth above. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Company will also retain information such as Your Device’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data (“Usage Data”) for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Your Rights under the CCPA

CCPA provides California residents with specific rights regarding their Personal Data.

If You are a resident of California, You have the following rights:

The right to correct. You have the right to request that we correct any inaccurate Personal Data we maintain about you.

The right know and data portability. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of Personal Data. Once We receive and confirm Your request, We will disclose to You:

• The categories of Personal Data We collected about You.
• The categories of sources for the Personal Data We collected about You.
• Our business or commercial purpose for collecting or selling that Personal Data.
• The categories of third parties with whom We share that Personal Data.
• The specific pieces of Personal Data We collected about You.
• If we sold Your Personal Data or disclosed Your Personal Data for a business purpose, We will disclose to You: the categories of Personal Data categories sold, and the categories of Personal Data categories disclosed.

The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your Personal Data from our records, unless an exception applies.

We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:

• Complete the transaction for which We collected the Personal Data, 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 bylaw.
• 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.

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by denying goods or services to You, charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties, providing a different level or quality of goods or services to You, or suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us by email at support@docupdate.io. Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your Personal Data.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Data 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 the required information if We cannot:

• Verify Your identity or authority to make the request
• And confirm that the Personal Data relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice. Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt. For data portability requests, We will select a format to provide Your Personal Data that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.