This document sets forth how Rx Studio Inc. (hereinafter, “Company”, “us” or “we”) collects, stores, uses and under what circumstances may disclose personal information obtained on our website at https://rx.studio (hereinafter, the “Website”), our platform at https://app.rx.studio (hereinafter, the “Platform”), and collectively all related products and services operated by us (hereinafter, the “Services”).
We are strongly committed to respect the privacy of our Website visitors and Platform users, and safeguarding all information transmitted while operating our Services.
WHAT INFORMATION DO WE COLLECT?
We automatically collect certain information when you visit, use or navigate the Website. This automatically collected information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your anonymized or actual IP address, browser characteristics, language preferences, referring URLs, approximate location, information about when and how you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.
You may also voluntarily and with your explicit consent provide further data and personal information to us on our Website, including your name, email address and affiliation, when subscribing to our newsletter to get product updated, or send us a message using our contact form, or entering data in our public demo application.
We collect further information on our users while operating the Platform for security and compliance reasons, which includes personal information, such as IP address, email address, first and last name, affiliation and country; user activity history, such as buttons and links clicked, and data entered in web forms; and health information and Protected Health Information (PHI, as defined by Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule) for the purpose of user-requested precision dosing calculations and PK/PD modeling.
We do not collect more health information than it is necessary to provide our Services.
WHAT COOKIES DO WE STORE?
HOW DO WE USE THIS INFORMATION?
We process information for the purposes based on legitimate business interests, the fulfillment of our contract with our Website visitors and Platform users, compliance with our legal obligations, and/or further consent.
We use the automatically collected data in our Services to:
- Help to keep our Services safe and secure.
- Diagnose any technical problems in our Services that might arise.
- Provide useful information about the way in which the Services are being used in the means of data analytics, for example to identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the user experience on our Website, Platform and other Services. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
We use personal information collected in our Services for a variety of business purposes described below. We process personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with the Website visitors and Platform Users, with explicit consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below:
- To send administrative information after consent. We may use the personal information to send product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- To provide you services, for example we need to collect and store personal information for authentication.
- To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract, e.g. keeping an audit log.
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
We use health information shared by our Website and Platform users as model inputs to PK/PD models to simulate drug dosing regimens as requested by the user.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations as per below:
- Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Third-parties integrated in our Website, Platform and Services for collecting, storing and processing information:
- Google Analytics provides us with information about how our Website is used, such as what countries our visitors and users are browsing from, and what pages are the most popular. The data gathered is anonymous and can not be used to identify individual users, as we don’t use tracking cookies, neither we log your actual IP address. You may block the collection of such data at https://tools.google.com/dlpage/gaoptout?hl=en.
- To standardize the collection of user events and actions performed in our Services for product analytics, customer support and platform auditability, we use Mixpanel, Inc. Mixpanel will receive your IP address, your user id, the timestamp of events and related properties (e.g. which page was viewed), and any data included in your forms. It will not be shared with third parties for marketing purposes. Mixpanel is based in the USA, and complies with the requirements of CCPA, GDPR, HIPAA and other international privacy frameworks. Find more information at https://mixpanel.com/legal/privacy-hub/.
- ReCAPTCHA is a service provided by Google that allows us to confirm that only real people (and not spambots) are able to submit our contact forms or sign up to our newsletters on our Website and Platform. When you tick the box that says “I’m not a robot”, Google place a cookie called NID in your browser, that communicates information such as what language your browser is set to, the date, how many mouse clicks you have made on the screen, and what other Google cookies you may have on your device – to calculate a risk score of human or bot behavior. Find more information at https://developers.google.com/recaptcha.
- We use Google Cloud Platform to authenticate our Platform users, to store data provided by the Platform users, and to handle contact form submissions on our Website, subscribe to product updates form on our Website and Platform, and to track events on our Platform that we need to keep for auditing purposes. Google will retain your IP, the originating page of the request, and all data included in your forms, including your user id. It will not be shared with third parties for marketing purposes. Find more information at https://cloud.google.com/security/privacy.
- We use Amazon Web Services to provide the computational back-end for the drug dosing simulations and to keep an audit log of user and system events in our Platform. Amazon will retain your IP, the originating page of the request, and all data included in your forms, including the user id, timestamp and other characteristics of an event. It will not be shared with third parties for marketing purposes. Find more information at https://aws.amazon.com/compliance/data-privacy-faq.
- To improve the reliability of sending automated product update emails to our subscribers, we use SendPulse Inc., who are based in the USA and have agreed to provide at least the same level of privacy protection for EU Personal Data as required under the U.S.-EU and U.S.-Swiss Privacy Shield frameworks. SendPulse will retain your IP address and all data included in our “subscribe to our newsletter” form in their log files on their server. This data is retained only for the purposes of delivering the email and providing us with information should there be a problem with the delivery. It will not be shared with third parties for marketing purposes. Find more information at https://sendpulse.com/legal/processing.
- To improve the reliability of receiving emails via our contact form and other personal messages, we use Mailgun Technologies, Inc, who are based in the USA and are participants in the EU-US Privacy Shield Framework. Mailgun will retain your IP address and all data included in our contact form in their log files on their server. This data is retained only for the purposes of delivering the email and providing us with information should there be a problem with the delivery. It will not be shared with third parties for marketing purposes.
Protected Health Information (PHI) is only shared with vendors who have been audited to meet the security standards required by the Health Insurance Portability and Accountability Act (HIPAA), and with whom we have a Business Associate Agreement (BAA) in place, including Amazon, Google, Mixpanel and Mailgun. The purpose of PHI disclosure is limited to treatment, payment and health-care operations.
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
We may transfer, store, and process your information in countries other than your own.
Our servers are located in USA. If you are accessing our Website from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above) in other countries.
If you are a resident in the European Economic Area, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
HOW LONG DO WE KEEP YOUR INFORMATION?
We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 6 years (as per Health Insurance Portability and Accountability Act (HIPAA) Audit Log Retention Requirements defined in Section 4.22 of NIST SP 800-66).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal and health information we process, and we only store, process and transmit protected health information in services which have been audited to meet the required security standards, such as Health Insurance Portability and Accountability Act (HIPAA).
However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your information, transmission of personal and health information to and from our Services is at your own risk. You should only access the Services within a secure environment.
DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact our Data Protection Officer.
WHAT ARE YOUR PRIVACY RIGHTS?
You have the right to access and delete any personal and health information you shared while operating our Services, subject to exceptions allowed by law (e.g. we need to keep audit logs of accessing Protected Health Information). You may request an automated deletion of your Platform account and data on your Profile page at https://app.rx.studio/profile/preferences, but you may also request to access and/or delete your information in writing addressed to our Data Protection Officer. We reserve the right to charge a fee for manual search and reporting of custom requests.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If you are a resident of California, you are granted specific rights regarding access to your personal information. California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, although we respect your DNT signals when recording your data in Google Analytics, but other means of data collection currently do not respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
DO WE MAKE UPDATES TO THIS NOTICE?
We may update this privacy notice from time to time. The updated version will be indicated by an updated date on the top of this page and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at firstname.lastname@example.org, or by post to
Rx Studio Inc.
340 S Lemon Ave, #2086
Walnut, CA 91789
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request by contacting our Data Protection Officer, and we will respond to your request within 30 days.