Privacy Disclosure For California Residents

These disclosures supplement the Privacy Policy (the “Policy”) of Edge Pharmaceuticals, LLC, a Florida limited liability company, (“Edge”), which can be found at https://edgepharma.com, or https://allergy.edgepharma.com (individually, a “Site”). These disclosures are provided pursuant to the California Consumer Privacy Act (the “CCPA”) and apply only to residents of California. Each capitalized term used, but not defined, in these disclosures shall have the meaning given to such term in the CCPA.

 

Required Disclosures

Categories of Personal Information Collected

The following categories of personal information are collected by Edge:

  • Identifiers (e.g., name, Internet protocol address, email address, physical address, and phone number);
  • Professional, Licensing, or Employment-Related Information;
    Education Information;
  • Bank account number, credit card number, debit card number, or other financial information;
  • Internet and Network Activity Information; and
  • Commercial Information.

 

Categories of Sources of Personal Information Collected

Edge obtains personal information from consumers using a Site, individuals or entities using a Site on behalf of consumers, or individuals or entities with whom or which Edge has a business relationship. Edge may also obtain personal information from customers, vendors, suppliers, and employees in the ordinary course of business.


Purposes for Collecting Personal Information


Edge uses personal information collected by it for one or more of the following purposes:

To achieve the purposes for which you, an individual or entity acting on your behalf, or an individual or entity with whom or which Edge has a business relationship, provided personal information;

  • To enable the employees at Edge to provide pharmaceutical products and services to consumers and its business partners;
  • To provide you with support, and to respond to your questions, regarding the products and services of Edge;
  • To record the use of a Site, facilitate account creation and logon procedures, to diagnose problems with a Site, and to improve and make each Site more useful to consumers;
  • To send e-mail messages, newsletters and other relevant information about the Edge’s products and services;
  • To process payments for Edge’s products and services;
  • To consider consumers for employment or employ consumers;
  • To administer employment benefits or distribute wages;
  • To respond to requests from law enforcement or other governmental authorities;
  • To comply with any applicable law or legal obligation;
  • To prosecute or defend itself in a legal dispute or proceeding; and
  • For any other business purpose permitted by the CCPA.


Categories of Third Parties with whom Edge Shares Personal Information


Edge does not sell any personal information to Third Parties. Edge may share personal information—including any category of personal information collected by Edge—with Third Parties that enable Edge to provide its products and services. Categories of Third Parties with whom Edge may share personal information include vendors that provide the following services to Edge: credit card and payment processing, data analysis, printing and marketing mailing services, electronic billing systems, accounting systems and services, business intelligence/financial analysis, health care billing systems, collaboration sites, faxing, email, email management and security, learning management systems, project management, digital dictation, scheduling systems, payroll and benefits systems, contact relationship management systems, new business intake systems, information governance systems, Cloud storage, applications for tracking and managing employee benefits data, government entities and data brokers.

Summary of Consumers’ Rights

The following is a summary of a consumer’s rights under the CCPA:

Access to Specific Information and Data Portability Rights

You have the right to request that Edge disclose certain information to you regarding your personal information collected by Edge as follows:

  • The categories of personal information collected about you;
  • The categories of sources of the personal information collected about you;
  • Edge’s business or commercial purpose for collecting or, if applicable, sharing your personal information;
  • The categories of third parties with which or whom Edge shares your personal information;
  • The specific pieces of personal information collected about you;
  • The categories of personal information, if any, Edge disclosed for a business purpose to a third party in the preceding 12 months.

Deletion Rights

You may request that Edge delete any of your personal information retained by Edge, subject to certain exceptions. Upon receiving and confirming your verifiable consumer request, Edge will delete (and direct its service providers to delete) such personal information from Edge’s (or such service providers’) records, except that Edge may deny your request if retaining the personal information is necessary for Edge or one of its service providers to:

  • Complete the transaction for which Edge collected the personal information, provide the business products and services requested by you, take actions reasonably anticipated within the context of Edge’s ongoing business relationship with you, or otherwise perform a contract between Edge and you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activity;
  • Debug products to identify and repair errors that impair intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her free speech rights, or exercise another right provided by law;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on the consumer’s relationship with Edge;
  • Comply with a legal obligation; and
  • Make other internal and lawful uses of personal information that are compatible with the context in which you provided it.

Verifiable Consumer Requests

To exercise your rights described in these disclosures, you must submit a verifiable consumer request to Edge as set forth in the Policy. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request relating to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows Edge to reasonably determine you are the person about whom Edge collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows Edge to properly understand, evaluate, and respond to it.

Edge cannot respond to your request or provide you with personal information if it cannot verify your identity or authority to make the request and confirm the personal information relates to you. Edge will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Edge’s Response

Edge endeavors to respond to a verifiable consumer request within 45 days of its receipt. If Edge requires more time (up to an additional 45 days), Edge will inform you of the reason and extension period in writing. Edge will deliver its written response by mail or electronically, at your option. Any disclosures provided by Edge will only cover the 12-month period preceding receipt of the verifiable consumer request. The response provided by Edge will, if applicable, also explain the reasons it cannot comply with a request. For data portability requests, Edge will select a format to provide your personal information that is readily usable and should allow you to electronically transmit the information from one entity to another entity without hindrance.

Edge does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Edge determines that any request warrants a fee, it will tell you why a fee is warranted and provide you with a cost estimate before completing your request.

No Discrimination

Edge will not discriminate against you for exercising any rights under the CCPA. In particular, if you exercise any such rights, Edge will not:

  • Deny you services;
  • Charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of products or services; or
  • Suggest that you may receive a different price or rate for products or services, or a different level or quality of services.


Revisions


Edge may revise these disclosures from time to time by posting the revisions on a Site. Any such revision will take effect immediately upon such posting, but will only relate to personal information collected after such revision is posted. It is your responsibility to periodically check each Site through which you conduct business for revisions to these disclosures.

Dated: July 27, 2020