Connecticut Consumer Privacy Addendum

Connecticut Data Privacy Act (the “CTDPA”)

CTDPA Privacy Notice

Last Updated: July 1, 2023

Terms Applicable to Connecticut Residents Only

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

Information That We May Disclose for a Business Purpose

For all categories of personal data collected (described in Section 1 of 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 Data

The CTDPA gives Connecticut consumers the right to opt out of the sale of their personal data. The CTDPA defines “sale” broadly to include different types of data sharing arrangements where the recipient can use the personal data 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 Out of the Use of Your Personal Data for Targeted Advertising

We use third party technologies, such as pixels, cookies and SDKs on Our website that collect the personal data of visitors to Our website. We use your personal data 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 data 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 data by these third parties for the purpose of serving you with Targeted 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 data.

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 Connecticut Consumer Rights

• Your Right to Request Deletion and Correction - You have the right to request that BuzzRx delete or correct any personal data 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 data in order to:
  

(i) comply with federal, state, or local laws, rules, or regulations;

(ii) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, local, or other governmental authorities; 

(iii) cooperate with law enforcement agencies concerning conduct or activity that the controller or processor reasonably and in good faith believes may violate federal, state, or local law; 

(iv) investigate, exercise, prepare for, or defend actual or anticipated legal claims; 

(v) conduct internal research to improve, repair, or develop products, services, or technology; 

(vi) identify and repair technical errors that impair existing or intended functionality; 

(vii) perform internal operations that are reasonably aligned with the expectations of the consumer based on the consumer's existing relationship with the controller; 

(viii) provide a product or service specifically requested by a consumer or the parent or guardian of a child, perform a contract to which the consumer is a party, or take steps at the request of the consumer prior to entering into a contract; 

(ix) protect the vital interests of the consumer or of another individual; 

(x) prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, or malicious, deceptive, or illegal activity; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action; 

(xi) process personal data for reasons of public interest in the area of public health, but solely to the extent that the processing:

(A) Is subject to suitable and specific measures to safeguard the rights of the consumer whose personal data are processed; and 

(B) is under the responsibility of a professional subject to confidentiality obligations under federal, state or local law; or

(xii) Assist another person with any of the activities set forth above.

• Your Right to Access - You have the right to access any of the following: (a) the categories of personal data We collected from you or processed, (b) the purpose for processing your personal data, (c) the categories of third parties with whom We shared your personal data, and (d) a list of categories of personal data We shared with third parties.
• Your Right to Opt Out of the Sale of Personal Data - You have the right to direct a company to not sell your personal data at any time (this is your right to “opt out”). We have sold your personal data (see above).
• Your Right to Opt Out of Targeted Advertising - You have the right to direct a company to not process your personal data for purposes of targeted advertising (this is your right to “opt out”). We have processed your personal data for purposes of targeted advertising (see above).
• Your Right to Opt Out of Profiling - You have the right to direct a company to not process your personal data for purposes of profiling that produce legal or similarly significant effects concerning you (this is your right to “opt out”). We have not processed your personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• Your Right to Data Portability - You have the right to obtain your personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. You may exercise this right no more than two times per calendar year.

Data Retention & Minimization

We retain personal data 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 data 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 data, We will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then We will securely store your personal data and isolate it from any further processing, until deletion is possible.

How to Exercise Your Rights

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

Click here to make a Data Rights Request. You can also exercise the right to opt out of selling your personal data and/or targeted advertising 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.

Send Us an email at: ConsumerRequests@BuzzRx.com

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

Or write to Us at:

CT 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 data. 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 CTDPA: (a) We will acknowledge receipt of 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 data; (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 data 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. If We decline to comply with your request, We will provide you with the right to appeal our decision. 

Who May Exercise Your Rights? 

You or your authorized agent may only make a request to exercise your rights on behalf of yourself. 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 try to 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. For data portability requests, We will select a format to provide your personal data to you. Responses to requests will be provided free of charge, up to one annually.  

Non-Discrimination

BuzzRx will not process Personal Data in violation of state or federal laws that prohibit unlawful discrimination against consumers. BuzzRx will not, based solely on the exercise of Your rights and unrelated to feasibility or the value of a service, increase the cost of, or decrease the availability of, the product or service. 

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://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.