California Consumer Privacy Addendum

California Privacy Rights Act (the "CPRA") Privacy Notice

CPRA Privacy Notice

Last Updated: May 19, 2023

Terms Applicable to California Residents Only

This provides additional terms that apply to residents of California. In the event of a conflict between this Addendum and Our Privacy Policy, this Addendum shall take precedence for California residents. In this Addendum only, any capitalized terms not defined in this Policy have the meanings set forth in the California Consumer Privacy Act (the “CCPA”).

If you work at BuzzRx or are a BuzzRx job applicant in California, click here to review your rights.

Information That We May Disclose for a Business Purpose

In the last 12 months, for all categories of personal information described in Our Privacy Policy, We disclose data to service providers and third parties to help Us accomplish each of the business purposes described in Section 3 of Our Privacy Policy. These service providers and third parties include data hosting providers, analytics service providers, security communication platforms, and marketing vendors.

Your Right to Opt Out of the Sale of Your Personal Information

The CPRA gives California consumers the right to opt out of the sale of their personal information. The CPRA defines “sale” broadly to include different types of data sharing arrangements where the recipient can use the personal information that they receive for the recipient’s own business purposes. We disclose names and email addresses to Our marketing partners so they can offer products or services that We believe may be of interest to Our customers, and We may receive compensation if the customer subsequently acts on that third-party offer. 

Your Right to Opt of the Sharing of Your Personal Information for Cross-Context Behavioral Advertising

We use third party technologies, such as pixels, cookies and SDKs on Our website that collect the personal information of visitors to Our website. We use your personal information collected in this manner for a variety of purposes, such as to understand how you use and interact with Our website, or to serve advertisements on Our website or other websites. Third parties, including Facebook, Bing and AdRoll, have pixels, cookies, SDKs or other tracking technologies on Our website and We use these third party technologies to measure and understand how you use or interact with Our website for performance, analytics and advertising purposes.

You should know that these third parties may collect your information from Our website and combine it with your personal information that they collect elsewhere on the Internet and use that information to provide measurement services and target ads to you. We may not have access to all of the information that these third parties collect about you. You may opt out of the collection and use of your personal information by these third parties for the purpose of serving you with Cross-Context Behavioral Advertisements by visiting http://www.aboutads.info/choices, or Interest Based Advertising by visiting: http://www.networkadvertising.org/choices/

In addition, you may explore the privacy notices of these third parties for a more complete understanding of what they do with your personal information.

NextRoll (AdRoll pixel): https://www.nextroll.com/privacy

Meta, Inc. (Meta Tracking Pixel): https://www.facebook.com/privacy/policy

Microsoft, Inc. (Bing Advertisements): https://privacy.microsoft.com/en-us/privacystatement

Complete List of California Consumer Rights

• Your Right to Request Deletion or Correction - You have the right to request that BuzzRx delete or correct any personal information which BuzzRx has collected about you. We will comply with such request, and direct Our service providers to do the same, subject to certain exceptions permitted by applicable law. For example, BuzzRx shall not be required to delete or correct such information if it is necessary for BuzzRx to maintain the personal information in order to:

1. complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of BuzzRx’s ongoing relationship with the consumer, or otherwise perform a contract between BuzzRx and the consumer;
2. detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
3. debug to identify and repair errors that impair existing intended functionality;
4. exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
5. comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
6. 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;
7. to enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business;
8. comply with a legal obligation; or
9. otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

• Your Right to Access - You have the right to access any of the following which occurred in the prior 12-month period: (a) the categories of personal information We collected from you, (b) the categories of sources from which the personal information was collected, (c) the business or commercial purpose for collecting your personal information, (d) the categories of third parties with whom We shared your personal information, (e) the specific pieces of personal information We collected from you (i.e., "data portability"), and (f) a list of categories of personal information We disclosed for a business purpose in the last 12 months.
• Your Right to Opt Out of the Sale or Sharing of Personal Information - You have the right to direct a company to not sell or share your personal information at any time (this is your right to “opt out”). We do sell and share your personal information (see above).
• Your Right to Limit Use of Sensitive Personal Information - You have the right to direct a company to limit use of your sensitive personal information at any time (this is your right to “opt out”). We have not used your sensitive personal information in the last 12 months.

Data Retention & Minimization

We retain personal information We collect from you for the period of time necessary to provide you with the goods or services that you have requested from Us. We will also retain your personal information where We have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements, to enforce Our agreements or comply with Our legal obligations). When We have no ongoing legitimate business need to process your personal information, We will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then We will securely store your personal information and isolate it from any further processing, until deletion is possible.

How to Exercise Your Rights

To exercise your California rights described in this Section, you may submit your request to Us by contacting Us at any of the following:

Click here to opt out of selling or sharing your Personal Information. You can also exercise this right by broadcasting the global privacy control signal. Click here or use a browser equipped with the Global Privacy Control browser extension. To learn more about global privacy controls visit globalprivacycontrol.org. Note that due to technological limitations, if you visit Our website from a different computer or device, you will need to rebroadcast the signal.

Click here to make other data rights requests.

Call our toll-free telephone number: 844-749-1019 (available Monday to Friday 9am to 5pm EST)

Send Us an email at: ConsumerRequests@BuzzRx.com

Or, write to Us at:

CA Privacy Rights
BuzzRx 
1 East Broward Boulevard
Suite 300 West
Fort Lauderdale, FL 33301

The Verifiable Consumer Request

BuzzRx must request certain information from a consumer who submitted the request, to verify the consumer is actually the consumer about whom BuzzRx has collected certain personal information. You must describe your request with sufficient detail to allow Us to properly understand, evaluate, and respond to your request.

When We receive your request to exercise your rights under the CCPA: (a) We will acknowledge receipt of your request within 10 business days and provide you with information about how we process your request; (b) We will respond to your request within 45 days after receipt of your request. Depending upon the nature and complexity of your request, We may extend the initial 45 days by an additional 45 days, and, if We do extend Our time to respond, We will notify you of the extension within the initial 45-day period; (c) We will try to match the information you provide in making the request with information We already maintain about you; (d) if required to verify your identity, We may ask you to provide additional information, including personal information; (e) We will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.

We will only use personal information We collect during the verification process for the purpose of verifying your identity. If you maintain an account with Us, We may use that account to respond to your request and/or verify your identity. If We are unable to verify your identity as required by applicable laws and regulations, We will decline to comply with your request, and let you know why.

Who May Exercise Your Rights? 

You or your authorized agent may only make a request to exercise your rights on behalf of yourself. An authorized agent must be registered with the Secretary of State in California to conduct business in California. If you choose to use an authorized agent, you must (a) verify your identity directly with BuzzRx or (b) directly confirm with BuzzRx that you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent. We may deny a request from an authorized agent if We do not have proof that they are authorized by you to act on your behalf.

When We Will Respond

We will confirm receipt of your request within 10 business days and provide information about how we will process your request. We will respond to your request within 45 days of receipt of your verifiable consumer request. BuzzRx reserves the right to extend this initial 45 days by an additional 45-day period when reasonably necessary. If We require additional time, We will inform you of the reason and extension period. Any disclosures We provide will only cover the 12-month period preceding Our receipt of your request. For data portability requests, We will select a format to provide your personal information to you. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

Non-Discrimination

The CCPA provides California consumers with the protection and peace of mind of knowing that BuzzRx will never discriminate against a California-based consumer because that consumer exercised any of his, her, or their rights under the CCPA. This prohibition on discrimination includes, but is not limited to:

(1) denying goods or services to the California consumer,

(2) charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

(3) providing a different level or quality of goods or services to the consumer;

(4) suggesting that a consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.

If We choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this Section.

Your Right to Appeal Our Decision 

If We reject your request, you have the right to appeal Our decision. Within ninety (90) days of your receipt of Our rejection of your request, you may submit a communication to Us appealing Our decision to reject your request. You may submit your appeal communication using the methods that We provide for the submission of consumer requests. In your appeal communication, please provide as much detail as possible about why you believe that We have rejected your request in error. It would be helpful if you were able to cite specific sections of the consumer data privacy law and guidance that applies to you.

Once We receive your appeal submission, We will have forty-five (45) days to reconsider your request and provide a written explanation to you. Depending on the nature and complexity of your appeal, We may need additional time to consider your appeal or communicate with you in order to further verify your appeal request. We may extend the time to respond to your appeal by an additional sixty (60) days. If we do extend the time to respond to your appeal beyond the original forty-five (45) days, We will provide you with notice of the extension and the reason for the extension within the original forty-five (45) days.

If We accept your appeal, We will take the action, or provide the information, that you have requested within the timeframe set forth above and provide you with a written explanation of Our decision. If we reject your appeal, We will neither take the action, nor provide you with the information that you have requested, but We will provide you with a written explanation about why your request was rejected.

In the event that you disagree with how We have handled your appeal, you have the right to contact your state attorney general. For more information about how to contact your state attorney general, please visit: https://oag.ca.gov/contact/consumer-complaint-against-business-or-company.

Shine the Light

Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom We may have disclosed your personal information within the past year for direct marketing purposes, and (b) a description of the categories of personal information disclosed, by contacting Us per the “Contact Us” Section 12 in Our Privacy Policy.