Last Updated:
February 24, 2020

This Privacy Policy explains the privacy practices of Flipt, LLC (together, “we,” “us,” or “our”) for users of the Flipt mobile application and the Fliptrx.com website (collectively the “Sites”) and all information therein (all of the foregoing collectively the “Services”). As used herein, “you” or “your” refers to the individual accessing or using the Services.

Flipt provides pharmacy benefit manager services in a unique and proprietary manner, and Flipt may grant you access to use the Services once you register as an account user (“User”). A “User” is a person who registers a User account (“Account”) through a portal available through the Sites, which also enables Users to access their Account to use the Services. Users may also access the Services on behalf of their covered dependents (“Covered Dependents”).

Our Commitment to Privacy

We are firmly committed to protecting the confidentiality and security of your Personal Information. Your ability to make informed choices about the uses of your information is important to us.  Flipt is committed to protecting your privacy and the Personal Information you provide to use the Services. This Privacy Policy sets forth our policy regarding the collection, use, disclosure, and protection of Personal Information. The terms of this Privacy Policy apply to information collected from you, unless different or updated terms are specified in another form or contract we provide to you or in an updated Privacy Policy.

What is Personal Information?

“Personal Information” includes any information which can be used to identify a person including name, date of birth, mailing address, social media profiles and other third party platform account identifiers, home phone number, mobile phone number, e-mail address, credit card information, and Social Security number.

How Your Personal is Collected?

Account Registration
We collect certain Personal Information when you sign up for your  Account, such as your name, address, e-mail address, phone number or mobile phone number, billing information, and other information that we deem relevant and important in order to provide the Services to you.

Mobile Access
When you access the Sites via a mobile device, we may receive information about your location (based on your IP address) and your mobile device, including various unique identifiers associated with your device, hardware type, and the version of your operating system. We may use this information to provide you the Services and related content based on your location.

Making Purchases
You may provide us with Personal Information on the checkout page of the Sites when ordering and paying for products or receiving rewards from your employer, where applicable. We use your Personal Information, as applicable to process your prescription drug information and claims in accordance your health plan’s contract with us and the prescription benefits provided under your health plan, and to transfer funds as you may direct us from time-to-time. We may request additional Personal Information as needed from time-to-time to provide the Services to you or to provide additional Services that you may elect.

Communicating With Us
In order to provide you with the Services, we may communicate with you through email or through text messaging to your mobile device. You acknowledge that electronic communications are not completely secure and that there may be some risks that your personal or prescription-related information may be seen or obtained by a third party.

You may review and adjust your communication preferences by logging into your Account. We may adjust the categories of communication preferences available to you through the Sites from time to time. These adjustments may, in certain instances, affect which communications you receive and the communication channels by which you receive them. Please note that if you opt-out of certain methods of communication, we may not be able to fully provide the Services or to provide certain Services at all.

How Your Personal Information is Used and Disclosed

In addition to using your personal information to provide the Services, we may use your Personal Information, in compliance with applicable law:

• to enhance or improve User experiences or our Services;
• to send emails about our Services or to respond to inquiries;
• to send emails, texts, and updates about Flipt and the Services and your related health plan or prescription information;
• to perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our Services;
• to enforce our rights and resolve disputes;
• for business purposes in a de-identified and aggregated form; and
• as otherwise described in the Terms of Use.

We never identify the User or your Personal Information other than as required to perform or improve the Services and only in compliance with applicable law. You acknowledge and agree that we may use, track, store, copy, distribute, broadcast, transmit, publicly display and perform, reproduce, digitally perform, modify, create derivative works of, and otherwise use and commercially exploit any feedback or other information that you provide to us via the Services in accordance with this Privacy Policy. If you are deemed to have retained, under applicable law, any right, title, or interest in or to any portion of such information or materials, you agree to and hereby do assign solely and exclusively to us all of your right, title and interest in and to such information or materials, without additional consideration, under applicable patent, copyright, trade secret, trademark and other similar laws or rights, in perpetuity. If such assignment is ineffective under applicable law, you hereby grant us the sole and exclusive, irrevocable, sub-licensable, transferable, worldwide, royalty-free license to reproduce, modify, create derivative works from, publish, distribute, sell, transfer, transmit, publicly display, use, and practice such information or materials, and to incorporate the same in other works in any form, media, or technology now known or later developed.

Covered Dependent Personal Information

The Services may include features through which a User (the “Primary Account Holder”) may be permitted to view the Personal Information or manage the benefits on behalf of Covered Dependents, including minors. Adult dependents may similarly become registered Users with the ability to access their own Personal Information. An adult Covered Dependent may grant or restrict access to the Primary Account Holder to view the granting person’s Personal Information. The Primary Account Holder has permission to view the Personal Information of minor Covered Dependents until such Covered Dependents reach the age of majority or otherwise qualify as emancipated minors under applicable law and provide Flipt with evidence of such emancipated status.

The availability of the Personal Information of the Primary Account Holder and other Covered Dependents may depend on the Primary Account Holder’s or Covered Dependents’ preferences, plan/program preferences, available website functionality, and applicable law.

Third Party Access to Your Information
Although you are entering into an agreement to disclose your information to us, we use third party individuals and organizations to assist us, including contractors, web hosting companies, and other vendors. These third parties will be required to protect your Personal Information in a manner consistent with this Privacy Policy.

Release of Your Information for Legal Purposes
At times, we may be legally compelled to release your information in response to a request from a government agency or in connection with a lawsuit or other legal action.

Other Disclosures of Your Personal Information
We will not use or disclose your Personal Information in a manner inconsistent with applicable law or this Privacy Policy.

Health-Related Personal Information
To the extent you submit Personal Information that constitutes Protected Health Information (“PHI”), use and disclosure of such PHI may be governed by the Health Insurance Portability and Accountability Act (“HIPAA”) and your health plan’s Notice of Privacy Practices, which you may obtain from your health Plan.  In order for Flipt to provide the full Services to you, you may be asked to sign a HIPAA Authorization Form which may be presented to you upon Account registration or thereafter.

If you have any questions about which policies apply to information you submit to us, please contact us at  [email protected].

How We Collect Your Non-Personal Information

IP Addresses and Log File Data
Whenever you use the Services, we may collect non-personal information from you, such as your IP address, referring URL, operating system, cookie information, and Internet Service Provider. You may be able to opt-out of certain third-party associations of such non-identifying information by following third party customization and/or opt-out options.

Cookies, Web Beacons, Browser Local Storage, and Similar Technologies
Cookies are small data files that are placed on your computer or other devices by websites that you visit. We may use cookies for various purposes including, but not limited to, remembering your preferences, maintaining User sessions, improving security of our Services, collecting usage information, and targeting ads. We may also employ session cookies provided by your browser to cache information related to your Account, including your non-personal information. Some of the vendors that support the Services may also use cookies, web beacons, and similar technologies to collect non-personal information from you.  This Privacy Policy does not cover cookie practices used by third-party service providers.

How We Use Your Non-Personal Information

Aggregate and De-identified Data
We sometimes create and analyze or aggregate de-identified information from information you provide.  Aggregated or de-identified data helps us understand trends and User needs so that we can better consider new products and services, and optimize existing products and services. Aggregate data is summary level data, which does not contain Personal Information. De-identified data is generally data that does not identify an individual and with respect to which there is no reasonable basis to believe that the information can be used to identify an individual.

How We May Disclose Your Non-Personal Information

We may disclose non-personal information to our affiliated companies, third parties who provide services to us, other parties that you have authorized, and for any lawful or legitimate business purposes.

Other Policies Pertaining to Privacy

Linking Policy
We may post links to third party websites on our Services. Additionally, other materials made available through our Services may contain third party website links or content. Any such links will take you to third party websites or content, and we bear no responsibility for the information collected or used by any such third parties. You should review the terms of use and privacy policies for any third party websites that you click on or visit.  Further, you release Flipt from any liability for the conduct or content of these third party websites.

Communications with You
Our communications to you may include messages sent through the use of landline phone, cellular phone, and text messages (including SMS and MMS).  We may use an automatic telephone dialing system (or “auto-dialer”), which may employ artificial or pre-recorded voice or “robotexts.” By submitting your Personal Information, including your phone number, email address, or other contact information, you are providing your express written consent to receive communications from us at the email address and telephone numbers you provide to us, including via text messages for which you may incur charges from your cell phone or wireless provider. You also represent and warrant that you are at least 18; you have not registered on a national or statewide Do Not Call list; you are the account holder for the email addresses and phone numbers you provide, or you have authorization from the account holder to give this consent; and the email addresses and phone numbers you provided are accurate, and you will let us know if you release them to another person or individual.

How often we send you text communications will vary based on the Services you request and how we provide such Services. Agreeing to text communications is not a condition of purchasing any property, goods or services from us. However, without the ability to communicate with you via text message, we will not be able to provide some of the Services to you. You may opt-out of receiving such text communications by removing your phone number from your Account or by contacting Flipt by email at  [email protected], but opting-out may impair our ability to provide, and your ability to use, the Services.

Security
Flipt has put into place security measures in an effort to protect Personal Information from loss, misuse or alteration while it is under our control. We use technical, contractual, administrative and physical measures in an effort to protect against unauthorized access to your Account and Personal Information. Only select Flipt staff have access to the Personal Information you provide. However, we make no representations as to the security or privacy of your Personal Information outside of the specific industry-standard mechanisms we have undertaken in good faith. Additionally, we have absolutely no control over the security of other third party sites you might visit, interact with, or do business with.

Breach of Personal Information
If your Personal Information is altered, destroyed, acquired, accessed, used, or disclosed in a manner not outlined by this Privacy Policy that compromises the privacy or security of the Personal Information, you agree that we may attempt to notify you electronically so that you can take appropriate protective steps, by posting a notice on the Site or sending an email to you at the email address you provide to us. The notification may be provided in one or more electronic mailings as information becomes available.

Depending on where you live or the type of information that is compromised, you may have a legal right to receive notice of a security breach in writing. To the extent required by applicable law, Flipt may report the breach of information to governmental authorities or other third parties.

If you believe there has been any breach of security of our sites, please email us at [email protected]

Your California Online Privacy Rights
We permit residents of California to use our Services. Therefore, it is our intent to comply with the California Business and Professions Code  22575-22579 If you are a California resident you may request certain information regarding our disclosure of Personal Information to any third parties for their direct marketing purposes. Various provisions throughout our Terms of Use address requirements of the California privacy statutes. In summary, you must presume that we collect electronic information from all visitors to the Sites. You may contact us at  [email protected]  with any questions.  Further, if you are a California resident, the California Consumer Privacy Act (CCPA) may provide you with additional rights regarding our use of your Personal Information. To learn more about your CCPA rights, visit https://fliptrx.com/privacy-notice-for-california-residents.

Children’s Privacy
Flipt is concerned about the safety and privacy of children online. Because of this, we will make all efforts to comply with the Children’s Online Privacy Protection Act of 1998 (COPPA).  We do not and will not knowingly contact or collect Personal Information from children under 13. Further, our Services are neither intended for nor designed to attract Users under the age of 18. Notwithstanding the foregoing, depending upon the functionality available in the Services, you, a partner, guardian, or similar legally authorized person (“Authorized Person”) may register a minor under their supervision for access to our Services. Upon turning 18, we will cease providing access to Services to the Authorized Person related to a minor that reaches the age of majority.

Retention of Information
Subject to any applicable business, legal, or regulatory requirements, we retain Personal Information only to provide the Services and to fulfill the intended purposes under the Terms of Use and Privacy Policy.  Thereafter, we securely destroy Personal Information when it is no longer required to fulfill the Services, our commitments to you, or to enforce our rights or meet our legal obligations.

Service and Privacy Policy Updates

We plan to regularly update and add new features to the Services. Because of this, Flipt reserves the right to revise its Privacy Policy at any time. Such amendments will be posted in the Privacy Policy section of the Sites. You can determine whether the Privacy Policy has been modified since you last visited the Sites or used the Services by checking the “Last Updated” legend at the top of the Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, or Flipt’s collection, use or disclosure of information, or if you think we may have incorrect Personal Information, or if you would like a copy of the Personal Information we hold on you, or if you have any concerns about how we have handled your Personal Information, please write to Flipt at: [email protected].