Phoenix LTC Privacy Statement
Certain Phoenix LTC products and services enable customers to collect and process information, including personal information used for identification and security purposes and health-related information. We process this information solely for the purpose of providing our products and services to our customers and only in accordance with their written instructions. The collection, use, retention, and deletion of this information is controlled by our customers and subject to their respective privacy policies. Please refer to our customers’ privacy policies for more information.
- Collection of Information
- Use of Information
- Sharing of Information Analytics
- Biometric Data
- Contact Us
COLLECTION OF INFORMATION
Information You Provide to Us
We collect information you provide directly to us. For example, we collect information when you contact us for information about our products and services, sign up for our newsletters and marketing communications, request a quote, create an account, make a purchase, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name and business contact information, such as your email address, postal address, phone number, and the name of your employer. If you purchase products and services from us, we also collect financial and commercial information about you, such as payment method, including credit card information or bank account information, date of purchase, and delivery and setup information, and other information related to your account, such as product and service preferences and any feedback you choose to provide.
Information We Collect Automatically When You Interact with Us
When you access or use our websites, we automatically collect certain information, including:
Device and Usage Information: We collect information about how you access and use our websites, such as your operating system version, IP address, unique device identifiers, and browser type. We also collect information about your activity on our websites, such as access times, pages viewed, links clicked, and the page you visited before navigating to our websites.
Information Collected by Cookies and Similar Tracking
Information We Collect from Other Sources
We obtain information from third-party sources. For example, we may collect your name and contact information from our distributors or marketing vendors.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address.
USE OF INFORMATION
We use the information we collect to manage our business relationship with you and provide our products and services. We also use the information we collect to:
- Create and maintain your account;
- Process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, and recall notices;
- Send you technical notices, security alerts, and support and administrative messages;
- Respond to your comments and questions and provide customer service;
- Communicate with you about products, services, and events offered by Phoenix LTC and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
- Monitor and analyze trends, usage, and activities in connection with our websites, products and services;
- Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Phoenix LTC and others;
- Debug to identify and repair errors on our websites, products and services;
- Comply with our legal and financial obligations; and,
- Carry out any other purpose described to you at the time the information was collected.
SHARING OF INFORMATION
We share personal information in the following circumstances or as otherwise described in this policy:
- We share personal information with vendors, service providers, and consultants that perform services for us, such as companies that assist us with web hosting, customer service, analytics, and marketing and advertising.
- We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
- We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Phoenix LTC, our users, the public, or others.
- We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
- We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
- Personal information is shared between and among Phoenix LTC and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
- We share personal information with your consent or at your direction.
- We also share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you.
Certain Phoenix LTC products, including StatSafe automated medication management system cabinets and kiosks, may utilize biometric data during login that employ devices and software that allow our customers to obtain information about their users’ fingerprints (“finger records”) for verification, access and security purposes. Phoenix LTC processes and stores users’ finger records to provide our products and services to our customers. In some cases, finger records are stored locally on customers’ devices or on customers’ networks. In those cases where biometrics are utilized by Phoenix LTC, finger records are encrypted at rest on the customer’s StatSafe device; on the Phoenix LTC cloud-based servers; and, while being transmitted between the two. This function is active as of StatSafe client software version 22.214.171.124 and above.
In all cases, Phoenix LTC’s customers are responsible for the collection, use, retention, deletion, and control of users’ finger records, and the privacy policies and notices of Phoenix LTC’s customers govern the collection, use, retention, deletion, and control of finger records. With respect to finger records under the control of Phoenix LTC, biometric images are kept only so long as the customer’s user is enabled on the device, as dictated by the customer. When the customer’s agent (e.g., the pharmacy or home administrator) disables the user, the biometric image is deleted from both the cloud-based servers and the customer’s StatSafe device. This function is active as of StatSafe client software version 126.96.36.199 and above.
Where required by law, it is incumbent upon the customer to obtain its user’s written consent to use that individual user’s biometric data in conjunction with applicable Phoenix LTC products.
Certain Phoenix LTC products, including StatSafe automated medication management system cabinets and kiosks, may utilize a non-biometric feature that takes a photograph of a customer’s user (“photograph records”) during login for confirmation (after the fact) and security purposes. Phoenix LTC processes and stores users’ photograph records to provide our products and services to our customers.
In some cases, photograph records are stored locally on customers’ devices or on customers’ networks. In those cases where photographs are utilized by Phoenix LTC, photograph records are only stored on the StatSafe client device while the image is being securely transmitted to the cloud-based servers. After transmission, the image is permanently deleted from the customer’s StatSafe device. This function is active as of StatSafe client software version 188.8.131.52 and above.
In all cases, Phoenix LTC’s customers are responsible for the collection, use, retention, deletion, and control of users’ photograph records, and the privacy policies and notices of Phoenix LTC’s customers govern the collection, use, retention, deletion, and control of photograph records. With respect to photograph records under the control of Phoenix LTC, Phoenix LTC will retain photograph records for a period of twenty-four (24) months on the cloud-based servers, and are encrypted at rest. After twenty-four (24) months, the pictures are permanently deleted. This function is active on all current StatSafe devices and coincides with the timeframe that the U.S. Drug Enforcement Administration (DEA) requires controlled substance records to be kept pursuant to 21 CFR §1304.4 Maintenance of Records and Inventories.
You may opt out of receiving promotional emails from Phoenix LTC by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
YOUR CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you. The CCPA requires that we provide transparency about any personal information we might “sell,” which broadly means scenarios in which Phoenix LTC has shared personal information with third parties in exchange for valuable consideration. Phoenix LTC does not, and will not, sell your personal information, and we will not discriminate against you if you exercise your rights under the CCPA.
2. What are cookies?
Cookies are small text files, which can be stored on your computer upon your visit to websites. Cookies usually have an expiration date. They can perform different functions but typically keep a record of websites visited.
Your internet browser downloads a cookie on the first visit to a website. The next time you visit the website with the same user device, this cookie as well as all the information stored in it will be resent to the website, which created it (first-party cookie). However, there is a possibility this information will be sent to another website managing it (third-party cookie).
This allows the website to recognize your browser and to remember your preferences, providing you in this way with more relevant content to your personal interests and needs.
Overall, cookies help us to improve user experience and enable us to improve the performance of the website.
3. Who installs cookies?
Cookies can be installed by Phoenix LTC or a third party:
- First-party cookies are installed and managed by Phoenix LTC. They are specific to the Phoenix LTC website which you visit;
- Third-party cookies are installed and managed by a third party. They are installed during your visit to a Phoenix LTC website and allow certain information to be sent to third parties upon your return to the Phoenix LTC website.
4. How long do cookies last?
Cookies can be temporary or persistent:
- Temporary or session cookies are temporarily stored in your computer or mobile device. As soon as you close your browser, these cookies are automatically deleted; and,
- Persistent cookies remain on your device for a longer time, even after you close your browser. They remain on your device until the expiration data is reached and then a new version of the cookie is installed or sometimes, or until you delete them manually. They make it possible to recognize you during a subsequent visit to the website.
The duration depends on the purpose for which certain types of cookies are installed in your computer. For example, a session cookie may be used to allow visitors to be recognized within a set of webpages, so that any choices or data selection made by that user are remembered from page to page.
Regardless of the purpose behind each specific cookie, Phoenix LTC takes into account the principle of data minimization when setting this duration. This means that, whenever possible, Phoenix LTC will opt for the shortest possible duration that still enables the function of the cookie to be performed.
5. For which purposes are cookies used by Phoenix LTC?
Furthermore, we collect data recorded by cookies to draw up anonymous, aggregated statistics or studies for Phoenix LTC websites and to ensure that its content and performance is relevant to our visitors.
6. What kind of cookies are used by Phoenix LTC?
Cookies can be described based on their function and intended purposes. Some cookies are considered essential to your navigation, while others are performance-measuring cookies. You can also have cookies of a functional nature, such as cookies that collect data for marketing purposes.
The types of cookies used by Phoenix LTC’s Website are the following:
- Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
- Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
- Functional Cookies: These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
- Targeting Cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
- Social Media Cookies: These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.
You have the possibility to withdraw the consent you provided for the placement of cookies by clicking on your cookie options at the bottom of this page.
When you opt-out, we will stop serving you targeted ads based on the data collected via your browser. We will place in your browser’s cookie an amount of data telling us that you have opted-out of Phoenix LTC’s website without archiving any other data with regard to you. We need this residual data to ensure our website no longer collects information about your interests. If you have previously opted in there will be residual cookies that you will need to delete. Please see section 8 for help.
8. How to manage and delete cookies?
You can manage and/or delete cookies if you desire to do so. For more information on the practical implications of changing cookie settings, you can consult this external page: https://www.allaboutcookies.org
In principle, web browsers are automatically configured to accept cookies. Nevertheless, you can configure your browser in a way that it informs you of each cookie sent, or to avoid them being stored on your hard drive. To better understand these parameters, please consult the following external pages:
- Cookies in Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
- Cookies in Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB&hlrm=nl
- Cookies in Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop?s=cookies&r=5&as=s&redirectslug=enable-and-disable-cookies-website-preferences&redirectlocale=en-US
- Cookies in Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac