I.   WHAT IS PERSONAL INFORMATION?

When we use the term “personal information” in this Privacy Policy, we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household or any other data or information that constitutes “personal data”, “personal information,” or “personally identifiable information.”

II.   OUR COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information in a variety of ways. For example, you may provide us with your personal information when you register for an account, post a review, send us messages, subscribe to our mailing lists, newsletters or other forms of marketing communications, or use some other feature of our Service.

We may link or combine your activities and information collected from you on our websites and mobile apps with information we receive from third parties, as well as information we collect automatically through online tracking technologies (defined below). This allows us to provide you with a personalized experience regardless of how you interact with us.

Personal Information Collected from You

We may collect the following categories personal information submitted to us by individuals through the Services:

• Contact Information, including first and last name, email address, postal address, and telephone We use this information to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.
• Account Information, including first and last name, email address, user ID and password, profile information, affiliations, payment and purchase history information, date of birth, images and video of you, and any other information you provide to us. We use this information to administer your account, provide you with the relevant service and information, communicate with you regarding your account and your use of the Service, and for customer support purposes. Please note we utilize a third-party provider to process payments on our behalf and do not accept payment directly through our Services.
• Demographic Information, such as your gender, age, ethnic origin, and race. We use this information to provide you with the relevant service and information.
• Health Information (with your permission and at your direction), such as your health records, your medical history, and any other health-related information you provide to us including such as your diet plan, the supplements you take or are recommended to take, and your lifestyle and exercise plan (collectively, “Health Information”). We use this information to provide you with the relevant service and information, as well as to send you information and updates on products or services we think may be of interest to you.
• Inquiry and Communications Information, including information provided in custom messages sent through the forms, in chat messages, to one of our email addresses, or via phone. This also includes contact information provided on our Services, and information provided in communications between you and us, and between you and Circle H Healthcare, PLLC Dba Little Drug Family Wellness Center Pharmacy. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users, and to manage and grow our organization.
• Newsletter, Marketing Emails, and Blog Information, including email address and applicable interests and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the “unsubscribe” link provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
• Reviews Information. We may also collect reviews and ratings you provide relating to our services or products. We use this information to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business.
• Business Representative Contact Information. If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement with us.
• Platform Provider as a Service Provider. We collect certain information about you on behalf of Circle H Healthcare, PLLC Dba Little Drug Family Wellness Center Pharmacy for which we are acting as a service provider. For example, when you use the Platform Provider app to communicate with Circle H Healthcare, PLLC Dba Little Drug Family Wellness Center Pharmacy we facilitate the sending of such messages and communications between you and Circle H Healthcare, PLLC Dba Little Drug Family Wellness Center Pharmacy. We do not share or process this information outside of our role as a service provider.
• Other Information that you provide to us online, by phone or in person, or as described in the Informed Consent, and use this information to respond to your request, provide you the requested services, and to inform our marketing and advertising campaigns.

Personal Information from Third Parties

We also obtain personal information from third parties, which we often combine with personal information we collect either automatically or directly from an individual.

We may receive the same categories of personal information as described above from the following third parties:

• Platform Provider Entities: We may receive personal information from other companies and brands owned or controlled by Platform Provider, and other companies owned by or under common ownership as Platform Provider. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
• Health Trackers and Apps: At your request, we may also collect Health Information gathered or generated by your use of any third-party health application, system, program and/or device that you connect to the We use this information to provide you with the relevant service and information.
• Social Media: Given the nature of social media, when an individual interacts with our Services through various social media platforms, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Facebook, LinkedIn, or other social networks, we will have access to any information that is available to the public, such as your user profile information and comments. We use this information to operate, maintain, and provide you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services. Your interaction with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information.
• Platform Provider’s Service Providers: Our service providers that perform services solely on our behalf, such as survey and marketing providers, collect personal information and often share some or all of this information with us. The information may include contact information, demographic information, payment information, information about your communications and related activities, and information about your orders. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
• Business Partners: We may receive your information from our business partners, such as companies that offer their products and/or services on our Services. We may use this information to administer and facilitate our services, your orders, and our marketing activities.
• Other Sources: We may also collect Personal Information about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and We use this information to operate, maintain, and provide you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

Through the provision of our Services, we may also process deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. Platform Provider commits to maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used by Platform Provider satisfies the requirements under applicable law.

Personal Information Automatically Collected

We, and our third-party partners, automatically collect information you provide to us and information about how you access and use the Services when you visit our services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies, and logging technologies (collectively, “tracking technologies”) and we may use third- party partners or technologies to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.

We, and our third-party partners, use tracking technologies to automatically collect usage and device information, such as:

• Information the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
• Information about the way you access and use our services, for example, the site from which you came and the site to which you are going when you leave our services, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the services from multiple devices, and other browsing behavior and actions you take on the Sites.
• Information about how you use the Service, such as the pages you visit, the links you click, the ads you view and click on, videos you watch, and other similar actions. We also collect information about your interactions with Circle H Healthcare, PLLC Dba Little Drug Family Wellness Center Pharmacy through the Service. We may also use third-party tools to collect information you provide to us or information about how you use the Service and may record your mouse movements, scrolling, clicks and keystroke activity on the Service and other browsing or search behavior. These tools may also record information you enter when you interact with our Service or engage in chat features through our Service.
• Information about your location, such as general geographic location that we or our third- party providers may derive from your IP address.
• Analytics information. We may collect analytics data to help us measure traffic and usage trends for the services and to understand more about the demographics of our users.

All of the information collected automatically through these tools allows us to improve our customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Sites and Services, and to improve the effectiveness of our Service, offers, advertising, communications and customer service. We may also use this information the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our services.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the services, as some features and services may not work properly. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see Third-Party Data Collection and Online Advertising below.

Additional Uses of Personal Information

In addition to the uses described above, we may collect and use personal information for the following purposes:

• Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions, including providing you with a white paper you have requested or an online product demonstration;
• Verify your identity and entitlement to products or Services, when you contact us or access our Services;
• Register you for and provide you access to events and webcasts;
• Communicate with you, including via email, SMS text message, push notifications, social media chats, and/or telephone calls;
• Request individuals to complete surveys about our organization, organizations we partner with, and Services;
• Send you technical notices (including sending you an SMS text code for verification purposes), security alerts and other support and administrative messages;
• For marketing and advertising purposes, including to market to you or offer you through email, phone or text message information and updates on products or services we think that you may be interested in from Platform Provider or our third-party partners (including, for example, clinical studies we think you might be interested in participating);
• Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services;
• Provide targeted ads on our behalf and on behalf of our customers;
• Conduct research and analytics, including on our customer and user base and our Services;
• Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
• Help maintain the safety, security and integrity of our property and Services, technology assets and business, including to prevent, investigate or provide notice of fraud or unlawful or criminal activity;
• To enforce our Terms of Use, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• Facilitate our services to Circle H Healthcare, PLLC Dba Little Drug Family Wellness Center Pharmacy;
• To fulfill any other purpose for which you provide personal information; and
• For any other lawful purpose, or other purpose that you consent to.

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Policy. In that case, the additional privacy notice will govern how we may process the information provided at that time.

III.  OUR DISCLOSURE OF PERSONAL INFORMATION

We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:

• Platform Provider Entities: We may share personal information with other companies owned or controlled by Platform Provider, and other companies owned by or under common ownership as Platform Provider, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
• Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
• Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
• Other Service Providers: In addition to the third parties identified above, we engage other third- party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, payment processing services, and administrative services.
• Circle H Healthcare, PLLC Dba Little Drug Family Wellness Center Pharmacy: We may share information from or about you such as your name and Circle H Healthcare, PLLC Dba Little Drug Family Wellness Center Pharmacy will also receive the information you communicate with them through the Platform Provider app.
• Ad Networks and Advertisers: We work with third-party ad networks and advertisers to deliver advertising and personalized content on other websites and services, and across other We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. For more information, please see the Third-Party Data Collection and Online Advertising section;
• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
• Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
  • in connection with the establishment, exercise, or defense of legal claims;
  • to comply with laws or to respond to lawful requests and legal process;
  • to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
  • to detect, suppress, or prevent fraud;
  • to protect the health and safety of us and others; or
  • as otherwise required by applicable law.
• With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications.

IV.   THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING

We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third- party advertisers to help identify you across devices, and we and these third-party advertising companies use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms.

We may also engage in the following:

• Social Media Buttons and Advertising. Our Services may include social media features, such as social media platform buttons (i.e., Facebook, LinkedIn, Instagram). These social media companies may recognize you and collect information about you when you click on these buttons, such as your device ID and the referring Your interactions with those features are governed by the privacy policies of those companies.
• Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Facebook, Instagram, LinkedIn, and other social media platforms. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.

To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising  Initiative’s  (NAI)  online  resources,  at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

V.  CONTROL OVER YOUR INFORMATION

You may control your information in the following ways:

• Access to Your Device Information. You may control the Services’ access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the Services to access your network devices and geolocation and to integrate with your other applications.
• Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
• Push Notifications. You can stop receiving push notifications from us by changing your preferences in the iOS or Android notifications settings menu.
• SMS Text Messaging. You may opt-out of receiving SMS text messages at any time. Please note that unsubscribing from promotional text messages will not prevent you from SMS texts from Platform Provider directly relating to your use of the Services, such as for account login (e.g. we may send you a security verification code). To unsubscribe from promotional SMS texts, you can reply STOP to any one of our promotional text messages. For more information, see our Terms of Use.
• Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at help@drowl.com. We may not be able to modify or delete your information in all circumstances.

VI. DATA RETENTION

We will usually store the personal information we collect about you for no longer than necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator, or other government authority.

To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal data is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal data and isolate it from further processing until deletion or deidentification is possible.

VII. CHILDREN’S PERSONAL INFORMATION

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.

VIII. LINKS TO THIRD-PARTY WEBSITES OR SERVICES

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties, including the Circle H Healthcare, PLLC Dba Little Drug Family Wellness Center Pharmacy. To learn about the personal information practices of third parties, please visit their respective privacy notices.

IX. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

X.  CONTACT US

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to at help@drowl.com