Data Protection

PLEASE READ AND REVIEW THE FOLLOWING PRIVACY STATEMENT CAREFULLY BEFORE USING THIS WEBSITE

This Privacy Statement sets forth the privacy policies and practices of PharmaLex GmbH. and its subsidiaries and affiliates (collectively, “PharmaLex”), as they relate to the collection, use and disclosure of Personal Data (as defined below) in connection with your use of our websites that link to this Privacy Statement (the “Websites”). Please read this Privacy Statement carefully and completely before using the Websites.

This Privacy Statement does not apply to Personal Data processed by PharmaLex:

  • When you apply for a job with us. Please see Applicant Privacy Statement.
  • In the course of your employment with us – whether as an employee or independent contractor.
  • Where we process Personal Data on behalf of and on the instructions of our customers (i.e., as a processor or a service provider). We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Statement.
  • That is subject to the Health Insurance Portability and Accountability Act and certain of laws related to clinical trials and research.

The terms “we,” “us,” and “our” refer to PharmaLex, and the terms “you” and “yours” refer to you, as user of the Websites. By accessing and using the Websites, you agree to the Terms and Conditions

What is Personal Data?

When we use the term “Personal Data” in this Privacy Statement, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual or household. The term does not include aggregated information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual and does not apply to other information that is excluded from privacy protections under applicable law (“Deidentified Data”).

Collection and Use of Your Personal Data


Personal Data We Collect Directly from You
We may collect Personal Data directly from you when you visit our Websites, choose to use services or participate in programs or otherwise provide Personal Data directly to us. Personal Data we collect directly from you may include:

  • Contact Information: including name, email address, postal address, and/or telephone number.
  • Account Information: including your user ID and password;
  • Financial Information: payment details you provide to us for purchasing goods or services;
  • Demographic Information: including date of birth and gender;
  • Communications Information: including information provided in messages sent through the forms, product and service preferences and/or behaviors; and future communication preferences;
  • Survey Information: information provided when you respond to questions submitted through surveys, e.g. name, contact details, date of birth and gender;
  • Marketing Information: personal details (name, contact preferences) provided in order to personalize marketing and promotional communications information based on your activities and interests to the extent it is necessary for legitimate interest purposes.

Personal Data We Automatically Collect About You
With your consent, we and our third-party providers may collect certain Personal Data from (or in connection with) your device when you visit the Websites, use our Services, or view online advertisements. This Personal Data includes:

  • Device Data: including internet protocol (IP) address, operating system and platform, device type and version, browser type and version, browser id, the URL entered and the referring/destination page, date/time of visit, language preferences, the time spent on our Websites, and any errors that may occur during the visit to our Websites.
  • Analytics data: including the path taken to/from our Websites, usage and activity on our Websites.
  • Location data:such as approximate geolocation.

We and our third-party providers may use cookies and other related technologies such as, web beacons to automatically collect this information. This helps us analyze how you use and interact with our Websites and distinguish you from other users. It also helps us and our third-party providers to determine products and services that may be of interest to you. For more information about these practices and your choices regarding cookies, please see our Cookie Policy.

Personal Data We Collect from Other Sources and Third Parties
We collect Personal Data from third parties, which we may combine with Personal Data we collect automatically or directly from a user. We may collect the same categories of Personal Data as identified above from the following third parties:

  • Your Employer / Company: we may receive your Contact Information from your employer / company where you interact with the Websites through your employer / company.
  • Business Partners: we may receive your Personal Data from our business partners.
  • Service Providers: our service providers that perform services on our behalf, such as analytics providers and payment processors, collect Personal Data and often share some or all of this information with us.
  • Information Providers: we may from time to time obtain information from third-party information providers to correct or supplement Personal Data we collect. For example, we may obtain updated Contact Information from third-party information providers to reconnect with an individual. We will obtain your consent to do so where required by applicable data privacy and security rules and regulations (“Data Protection Laws”).
  • Other Sources: We may also collect Personal Data from publicly available sources or through transactions (e.g., mergers and acquisitions). We will obtain your consent to do so where required by applicable law.

Please be advised that any Personal Data provided to us by a third party may also be subject to that third party’s privacy policy.

Some of the Personal Data (e.g., financial account and location data) that we collect, and process may be considered sensitive Personal Data in certain jurisdictions. The processing of such data is necessary for providing services to you and/or personalizing our services and Websites. We adopt appropriate security measures to protect the Personal Data we process, including sensitive Personal Data. We do not expect that our processing of sensitive Personal Data would impact your rights and interests adversely.

Retention

Personal Data will be stored and kept as long as needed to carry out the purposes described in this Privacy Statement or as otherwise required by applicable Data Protection Laws. Because these needs can vary for different data types in the context of different services, actual retention periods may vary.

When determining the retention period, we consider various criteria, such as the type of service requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with services, the impact on the services we provide if we delete some Personal Data from or about you, mandatory retention periods provided by applicable law, including Data Protection Laws, and the U.S. statute of limitations.

Unless we are required or permitted by law to keep your Personal Data for a longer period of time (e.g., in pending litigation matters or where the law requires us to), when this Personal Data is no longer necessary to carry out the purposes for which we process it, we will delete your Personal Data or keep it in a form that does not permit identifying you. If there is any Personal Data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of that Personal Data.

Categories of Personal Data We Sell or Share and Related Information

When we engage in digital advertising, we may sell the following categories of Personal Data (according to the broad definition of “sell” under select state Data Protection Laws) or we may share (according to the broad definition of “share” under select state Data Protection Laws) them for purposes of cross-context behavioral advertising: personal identifiers (IP address); and internet or other electronic activity information.

These categories of Personal Data are sold to or shared for cross-context behavioral advertising to advertising networks and other companies that facilitate digital advertising. We engage in such sales and sharing to facilitate digital advertising that is able to reach people that are most likely to be interested in the services we provide.  We do so by allowing third parties to place cookies or other tracking technologies on our website that may collect information about your online activities over time and across different websites or applications.  For more information about the use of cookies and other tracking technologies, see the section “Cookies, Web Beacons and Other Technologies” below.

In certain jurisdictions, you may opt out of such sales and sharing of Personal Data, by clicking here.

 

Purposes and Legal Bases for Processing Personal Data

We process Personal Data for the following purposes (and as required where you or we are located in the EEA/Turkey/UK in reliance on the following legal bases):

Purposes of Processing Categories of Personal Data Legal Basis for Processing (where you OR we are located in the EEA / UK / Turkey)
Create and manage user accounts (including, verification / authorization for the same) Name, address, contact number, country, date of birth, email, username. Where necessary for the performance of a contract entered into with a user (Article 6(1)(b) GDPR)
Send you service-related communications and respond to your communications made via the Websites Name, contact address, email, contact number. We have a legitimate interest to respond to your communications and keep records in case of complaints / legal claims (Article 6(1)(f) GDPR)
Administer, analyze, improve and personalize our Websites (including, testing, trouble-shooting and research) Name, contact address, email, username. We have a legitimate interest in providing the Websites and process Personal Data to see if and how our Websites can be improved, so that we can offer you a better user experience in the future (Article 6(1)(f) GDPR)
To ensure network and information security, including monitoring authorized users’ access to our Websites for the purpose of preventing cyber-attacks, unauthorized use of our systems and Websites, prevention or detection of crime and protection of Personal Data Name, email, username. We have a legitimate interest in ensuring our systems / Websites are secure and that individuals are using our systems / Websites correctly and in compliance with our Terms of Use (Article 6(1)(f) GDPR)
Help maintain the safety, security and integrity of our property, technology assets, and business Name, contact address, email, username. We have a legitimate interest in ensuring our property / business are secure (Article 6(1)(f) GDPR)
To defend and enforce our rights (and those of third parties) including, against legal claims, and to manage regulatory matters, investigations, data breaches, and/or data subject requests Name, address, contact number, country, date of birth, email, username, health data (if applicable). We have a legal obligation to do so (e.g., respond to data subject requests) (Article 6(1)(c) GDPR)

We have a legitimate interest to manage our business and to ensure that all investigations and proceedings etc. are managed efficiently and effectively (Article 6(1)(f) GDPR)
Register you for and provide you access to events Name, address, contact number, country, date of birth, email, username. With your consent (Article 6(1)(a) GDPR)
Request users to complete surveys Name, address, contact number, country, date of birth, email, username. With your consent (Article 6(1)(a) GDPR)
For marketing and advertising purposes, including to offer you through email, information and updates on products or services we think that you may be interested in Name, email, username. Where required, with your consent (Article 6(1)(a) GDPR) or otherwise in reliance on our legitimate interests i.e., to find, customize, and offer products and services we hope you find useful and relevant and in turn, provide you with quality customer service (Article 6(1)(f) GDPR)
Measure the effectiveness of the advertising we serve to you and others Name, contact address, email, username. With your consent (Article 6(1)(a) GDPR)
To enable any due diligence and other appraisals or evaluations for any actual or proposed merger, acquisition, financing transaction or joint venture contemplated by PharmaLex Name, address, contact number, country, date of birth, email, username. We have a legitimate interest to manage our business (Article 6(1)(f) GDPR)

 

 

Subject to applicable Data Protection Laws, you have a right to object to the processing of your Personal Data where that processing is carried out for our legitimate interests. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, updates to features of the Websites, technical and security notices).

In certain jurisdictions, applicable Data Protection Laws may require that we obtain your consent for the processing of your Personal Data. In such circumstances, we will process your Personal Data based on your consent. In appropriate circumstances, your consent may be implied by your conduct.

Consequences of Not Providing Personal Data

Where we need to collect the abovementioned categories of Personal Data by virtue of a legal obligation or in light of a contract entered or to be entered into with you, and you do not provide this Personal Data when requested, we may not be able to comply with our legal obligations, provide you with the services or perform the contract we have or are trying to enter into with you. In such case, we may have to terminate our relationship with you.

Sharing Your Personal Data

We may share your Personal data with the following third parties:

  • PharmaLex Affiliates: we may share your Personal Data with our subsidiaries and affiliates for the same purposes as are described above.
  • Service Providers: we engage third-party service providers to perform business / operational services for us or on our behalf and to whom we will disclose Personal Data. These third parties include, for example, providers of website hosting, IT services, analytics services, and payment processing services.
  • Advertising Partners and Ad Networks:we work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Websites. These parties may collect Personal Data directly from a browser or device when a user visits our Websites e.g., through cookies. This Personal Data is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. Please see our Cookie Policy for more information.
  • Your Employer / Company: we may disclose your Personal Data to your employer / company if you interact with our Websites through your employer / company.
  • Transactions: we may disclose Personal Data to a third-party during negotiation of, in connection with, or as an asset in a corporate business transaction. Personal Data may also be disclosed in the event of a transfer, sale or merger of all or a portion of PharmaLex’s assets, in the event of an insolvency, bankruptcy, or receivership or other corporate change involving us or our affiliates.

Disclosing information as required by law and similar disclosures

We may disclose Personal Data we have about you: (i) if we are required to do so by law, regulation, or legal process, such as a court order or subpoena; (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) when we believe a disclosure is necessary or appropriate to protect against or respond to physical, financial or other harm and injury (iv) in connection with an investigation or suspected or actual unlawful activity.

 

Aggregated information

We may share anonymous usage data on an aggregate basis with third parties to help us perform analysis and make improvements. Additionally, we may share anonymous usage data on an aggregate basis in the normal course of operating our business; for example, we may share information with subsidiary organizations to show trends in the use of our services.

 

Other disclosures

At your direction or request, or when you otherwise consent, we may share your Personal Data for purposes other than those that are listed above.

If you would like to obtain information regarding the names and contact details of the parties with whom we share your Personal Data, their processing purpose and method, the categories of Personal Data shared with them, and the method and procedures for exercising your rights with them, please contact us using the contact details set out at the end of this Privacy Statement. Please note however that we may not be able to fulfil this request in all instances.

Your Privacy Rights

To see information regarding your individual rights as a resident of California, U.S., please see the State Supplement to Privacy Statement and the Sections herein titled “Rights Related to California Resident Personal Data Held by Us” and “Exercising Your Rights and How We Will Respond.” The contents of this Section are not applicable to you.

Depending on where you are located and/or the location of the PharmaLex company you are interacting with, you have certain privacy rights with respect to your Personal Data, including as follows:

  • Right to Object: you have the right to object at any time to the processing of Personal Data on grounds relating to your particular situation, including a right to object to the processing of your Personal Data for processing performed on the basis of legitimate interest, unless we are able to demonstrate overriding compelling legitimate grounds.
  • Right to Know/Access: You have the right to obtain confirmation from us as to whether we are processing your Personal Data and the right to access and receive a copy of such Personal Data.
  • Right to Delete/Erasure: In some cases, you may request the deletion or erasure of Personal Data concerning you.
  • Right to Rectify/Correct Inaccurate Information: If we process inaccurate, incomplete, or outdated Personal Data, you have the right to rectification.
  • Right to Withdraw Consent: Once you have consented to the collection of your Personal Data, you may withdraw your consent at any time. Please note that your withdrawal of consent would not affect the lawfulness of processing based on consent before it was withdrawn.
  • Right to Data Portability: You have the right to receive the Personal Data concerning you in a structured, commonly used and machine-readable format and the right to transmit that information to another company where feasible.
  • Right to Restrict: You have the right to restrict us from processing Personal Data under certain circumstances e.g. you contest the accuracy of your Personal Data or when you believe that we are processing your Personal Data beyond the original purpose.
  • Right to Lodge a Complaint: You have the right to lodge a complaint with the competent data protection supervisory authority. You can, for example, contact the supervisory authority in the EU Member State of your residence, place of work or place of alleged infringement.
  • Right to Opt-out of the Sale of Personal Data: We do not sell your personal data as defined under California and other US State Laws and we do not collect any Sensitive Personal Information for the purpose of inferring characteristics about you. If you consent, we do share certain information with business partner organizations to market our services, but you can opt-out of such sharing by rejecting cookies that are not strictly necessary as described in our Cookie Policy.
  • Certain States in the United States e.g. Colorado, Connecticut and Virginia allow you to appeal instances of where we are not able to honor or exercise your Personal Information rights. If you are in one of these States and wish to appeal a decision we made with respect to exercising a right about your Personal Information, you must email us at privacy@Cencora.com and (a) in the email subject line include your State of residence and the words “Appealing Rights Decision”, and (b) in the email body provide an explanation of the basis of your appeal. More information is available in the State Supplement to Privacy Statement.
  • Right to Non-Discrimination: we will not discriminate against you for exercising any of your privacy rights.

You may exercise these rights by contacting PharmaLex under the “Contact Us” section below or via the forms provided under Rights Requests. In order to protect your privacy, we may take steps to verify your identity before fulfilling your request.

 

French users: right to give specific instructions concerning the fate of your Personal Data after your death.

 

Turkish users: details of the recipients to whom we transfer Personal Data (in country or abroad), claim compensation for damage arising from the unlawful processing of your personal data, object to the automated processing of your personal data where a negative result is produced.

We also refer you to the U.S. State Supplement to this Privacy Statement for information related to privacy laws of certain U.S. States.

International Transfer of Personal Data
The Personal Data we collect may be transferred to and stored in countries or provinces outside of the jurisdiction you are into locations where we and our third-party service providers have operations, including in the USA. For example, if you are accessing a Website hosted in the USA (e.g., by PharmaLex) from the EEA, UK or Switzerland, your Personal Data will be processed outside of the EEA, the UK and Switzerland, respectively.

PharmaLex has entered into intra-group data transfer agreements to ensure the lawful transfer of Personal Data between the PharmaLex companies.

European Transfers: If you are located in the EEA, UK, Switzerland or other countries which restrict the transfer of Personal Data, we comply with applicable data protection laws when transferring your Personal Data outside of these areas. In particular, we may transfer your Personal Data to countries for which adequacy decisions have been issued; implement appropriate and suitable safeguards such as the European Commission’s Standard Contractual Clauses or the Addendum B.1.0 issued by the Information Commissioner of the UK for the transfer of Personal Data to our U.S. headquarters, other offices or third parties, where applicable, or where required, we will ask you for your prior consent.

Data Transfers outside of China: Where we transfer Personal Data to a recipient outside of China, we will comply with the applicable requirements under China’s data protection laws, including the Personal Information Protection Law, and take necessary measures to ensure that the data processing activities of the recipient meet the applicable protection standards stipulated by China’s data protection laws.

If you are a resident of the People’s Republic of China and are accessing our Websites, you should be aware that by doing so you are exporting your Personal Data from China and you consent to PharmaLex processing your Personal Data in accordance with this Privacy Statement. If you do not wish PharmaLex to process your Personal Data, you may withdraw your consent by using the contact details below or email privacy@cencora.com

Other Jurisdictions: For other jurisdictions PharmaLex is committed to ensuring the security of your Personal Data while it engages in any cross-border transfers and is going to take all necessary measures required under the applicable legislation including obtaining your prior consent that is informed, freely given and specific.

You may contact us using the details below to obtain information regarding the safeguards we use to legitimize the cross-border transfer of Personal Data.

Security of Your Personal Data
We use appropriate technical, administrative and physical safeguards to protect Personal Data from loss, misuse or alteration. We limit access to Personal Data to those employees, agents, contractors and other third parties who have a business need to know. You acknowledge and agree that no organization can guarantee the absolute security of Personal Data, and any transmission of Personal Data is at your own risk.

Protection of Children
PharmaLex will not knowingly collect, use or disclose Personal Data from a Child without obtaining prior consent from a person with parental responsibility (parent or guardian) where required by applicable law. PharmaLex abides by laws protecting the privacy of Children. Should a user whom we know to be under 18 provide Personal Data to us, we will use that information only to respond directly to that Child to inform him or her that we must have parental consent before receiving information about him or her and then delete it.

Links to Other Sites
Our Websites may provide links to third party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Statement, this Privacy Statement does not apply to, and we are not responsible for, any Personal Data practices of third-party websites and online services or the practices of other third parties. To learn about the Personal Data practices of third parties, please read their respective privacy policies.

Modifications and Updates to Privacy Statement
PharmaLex may update and modify this Privacy Statement from time to time. If we make material changes to this Privacy Statement, we will notify individuals by email to their registered email address, by prominent posting on our Websites, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Contact Us
If you have any questions about our privacy practices or this Privacy Statement, or if you wish to submit a request to exercise your rights as detailed in this Privacy Statement, please contact us using the contact details set out below.

Email address:  The Data Protection Officer may be contacted at privacy@cencora.com.

 

 

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS ON PERSONAL DATA PROCESSING AND PRIVACY RIGHTS

Disclosure of Personal Data For Business Purposes in the Past 12 Months

The following chart describes the categories of Personal Data that we disclosed to third parties for a business purpose in the 12 months prior to the date of this Notice:

Categories of Individuals’ Personal Data Categories of Third Parties with Which We Shared Personal Data for a Business Purpose
Personal identifiers: name; email address; account information; your home or billing address; telephone numbers; customer number; information related to customer reviews; IP address.

 

 Service providers that process payments, verify customer information, manage customer information and provide customer service (including through our call center and chat features), facilitate email communications, provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, provide analytics information, and provide legal and accounting services.
Protected class information: sex/gender; age. Service providers that provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, and provide analytics information
Commercial and financial information: payment details; product and service preferences and/or behaviors; and future communication preferences.

 

 Service providers that process payments, verify customer information, manage customer information and provide customer service (including through our call center and chat features), facilitate email communications, provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, provide analytics information, and provide accounting services
Internet or other electronic activity information: your device and browser type; your browsing and search history on our website; and information regarding your interaction with our Websites and our advertisements; operating system and platform; device type and version; browser type and version; browser id; the URL entered and the referring/destination page; date/time of visit; language preferences; the time spent on our Websites; and any errors that may occur during the visit to our Websites. Service providers that provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, and provide analytics information.


Business Purposes for Such Disclosures

We disclosed the aforementioned categories of personal data to the categories of third parties identified above for the following purposes: to manage customer, supplier and vendor accounts and relationships; process payments; verify customers’ identities; fulfil orders and transactions; engage in advertising and marketing; operate our IT systems and secure our systems and facilities; prevent fraud and other illegal activities; and to obtain professional advice, such as about legal and accounting matters.

Additional Information About How We May Disclose Personal Data

We may also share your personal data as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your personal data with third parties to help detect and protect against fraud or data security vulnerabilities. And we may share or transfer your personal data to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.

Cookies and Other Tracking Technologies

We may use cookies, pixel tags, web beacons and other similar tracking technologies (“tracking technologies”) to automatically collect information through our website. Tracking technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that record certain pieces of information when you visit our website. We may use these tracking technologies to help identify irregular behavior, prevent fraudulent activity and improve security, as well as making it possible for you to save your preferences and help us understand how you interact with our website.

We also allow third parties to use tracking technologies on our website for analytics and advertising.  They assist in helping display advertisements, tailor advertisements to your interests and to assist in determining if you require assistance or are having problems navigating on our website.   Some of these third parties are our service providers that may use certain technologies to record your interactions with the sites, including without limitation, your keystrokes and mouse clicks, and information about when, how and from where you accessed our sites.  This information is used to help us manage our sites and provide a good user experience.  The service providers we use in this regard agree not to sell or disclose any of the recorded information to third parties (other than subcontractors who assist in providing this service to us or for legal compliance purposes at our direction).  Other third parties use the tracking technologies to collect information about how you interact with other website and advertisements across the Internet to provide advertising that is tailored to your interests and which may appear on our website or on other website or platforms.

You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com.

Rights Related to California Resident Personal Data Held by Us

If you are a California resident, you have certain rights that are described in this section of the Policy.

Your Right to Access Information We Collect and Share About You

We are committed to ensuring that you know what personal data we collect. To that end, you can ask us for the following information from us with respect to the personal data that we have collected about you in the 12 months prior to our receipt of your request:

  • Specific pieces of personal data we have collected about you;

 

  • Categories of personal data we have collected about you;

 

  • Categories of sources from which such personal data was collected;

 

  • Categories of personal data that the business sold or disclosed for a business purpose about you;

 

  • Categories of third parties to whom the personal data was sold or disclosed for a business purpose; and

 

  • The business or commercial purpose for collecting or selling your personal data.

Your Right To Request Deletion of Personal Data We Have Collected From You

Upon your request and subject to exceptions in the law, we will delete the personal data we have collected from you.

Your Right to Request to Correct Personal Data We Hold About You

You have the right to request that we correct personal data we hold that you believe is not accurate.  We will take steps to determine the accuracy of the personal data that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the personal data you have identified as being incorrect.  We may ask that you provide documentation regarding your request to correct to assist us in evaluating the request.

Your Right to Ask Us Not to Sell or Share Personal Data We Have Collected About You

With respect to those categories of personal data that we sell to third parties or share with third parties for the purpose of cross-context behavioral advertising, you have the right to opt out of such sales and sharing.

Opt-out Preference Signals

An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of consumers and communicates a consumer’s choice to opt out of the sale and sharing of personal data for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests.  The signal can be set on certain browsers or through opt-out plug-in tools.

We recognize the Global Privacy Control signal and do so at the browser level.  This means that if the signal is sent through a specific browser, we will recognize it for that browser only.  If you would like more information about opt-out preference signals, including how to use them, the Global Privacy Control website has such information (https://globalprivacycontrol.org/).

California Shine the Light

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents to annually request, free of charge, information about the personal data (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year.  To make a request, please contact us at privacy@cencora.com.

Our Commitment to Honoring Your Rights

If you exercise any of the rights explained in this Privacy Notice, we will continue to treat you fairly.

Exercising Your Rights and How We Will Respond

To exercise your access or deletion rights, or to ask a question about your data subject rights, email us at privacy@cencora.com, or click here.

We will first acknowledge receipt of your request within 10 business days of receipt of your request.  We will then provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances.  If we expect your request is going to take us longer than normal to fulfill, we will let you know.

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations.

In some cases, the law may allow us to refuse to act on certain requests.  If this is the case, we will endeavor to provide you with an explanation as to why.

Verification of Identity – Access or Deletion Requests

We will ask you for two or three pieces of personal data and attempt to match those to information that we maintain about you.

If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request.  We will notify you to explain the basis of the denial.

Authorized Agents

You may designate an agent to submit requests on your behalf.  The agent can be a natural person or an entity that is registered with the California Secretary of State.

If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process.  Specifically, if the agent submits requests to access, know, correct, or delete your personal data, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf.  We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney under the California Probate Code. Any such requests will be processed in accordance with California law pertaining to powers of attorney.

Do Not Track Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals.

Personal Data of Minors

We do not advertise our positions to minors under 16, and we do not knowingly collect or Sell, or Share the Personal Data of minors, including minors under 16 years of age.

Accessibility

We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at info@cencora.com

 

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