Virginia Consumer Privacy Addendum

Virginia Consumer Data Protection Act (the "CDPA") Privacy Notice

CDPA Privacy Notice

Last Updated: May 19, 2023

Terms Applicable to Virginia Residents Only

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

Information That We May Disclose for a Business Purpose

For all categories of personal data (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 CDPA gives Virginia consumers the right to opt out of the sale of their personal data. The CDPA 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 data 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 Virginia Consumer Rights

• Your Right to Request Deletion or 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:

1. Comply with federal, state, or local laws, rules, or regulations;
2. Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, local, or other governmental authorities;
3. 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 laws, rules, or regulations;
4. Investigate, establish, exercise, prepare for, or defend legal claims;
5. Provide a product or service specifically requested by a consumer, 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;
6. Take immediate steps to protect an interest that is essential for the life of the consumer or of another natural person, and where the processing cannot be manifestly based on another legal basis;
7. Prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any illegal activity; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action;
8. 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 if the deletion of the information is likely to render impossible or seriously impair the achievement of the research and the consumer has provided consent; 
9. Assist another controller, processor, or third party with any of the obligations under the Virginia Consumer Data Protection Act;
10. Conduct internal research to improve or repair products, services, or technology;
11. Identify and repair technical errors that impair existing or intended functionality; or
12. Perform internal operations that are reasonably aligned with the expectations of the consumer based on the consumer's existing relationship with the controller or are otherwise compatible with processing data in furtherance of the provision of a product or service specifically requested by a consumer or the performance of a contract to which the consumer is a party.

• Your Right to Access - You have the right to access any of the following (a) the categories of personal data We processed about you, (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 disclosed to third parties.
• Your Right to Opt Out of 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 do sell 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 information 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 in furtherance of decisions 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. 

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 Virginia 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:

VA 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 CDPA: (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 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 may only make a request to exercise your rights on behalf of yourself. 

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 twice annually. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

Non-Discrimination

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

(1) denying goods or services to the Virginia 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://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.