December 30, 2022
Alto is a licensed pharmacy and offers pharmacy delivery services. By using Alto’s Services, you consent to the data practices described in this statement.
Scope of This Notice
Collection of Personal Information
Information You Provide
In this Policy, “Personal Information” means information that relates to an identified or identifiable individual. We may collect Personal Information from you (like your name, date of birth, email address, credit card information, phone number, and delivery address) when you register for an account, sign up for an event or newsletter, or communicate with us such as by email or SMS (text). In order to provide you with the prescription delivery services, you will need to provide us with certain medical information such as your physician's name and address, prescription information, insurance information, and in some cases, medical history (collectively, your "Personal Information").
Information We Collect Automatically
We may automatically collect information about your computer or mobile device hardware and software. This information may include: your IP address, device identifier, browser type, domain names, access times, referring website addresses, and information about your activity on Alto’s Services. This information is used for the operation of the Services, to maintain quality of the Services, and to provide general statistics regarding use of the Alto Services.
Cookies and Other Technologies
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.Analytics. We may use Google Analytics or other analytics providers to help us understand the use of our Services. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Services or on third-party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.If you would like to opt out of the Technologies we employ on our Services you may do so by blocking, deleting, or disabling them as your browser or device permits. Note that if you opt out of operationally necessary Technologies, the Services may not perform properly.
How Personal Information May Be Used
To Provide Services or Information Requested. Alto collects and uses your Personal Information to operate its Services and deliver the information and Services you have requested, including fulfilling your prescriptions and delivering them to you. The information we collect or maintain is subject to our Notice of Privacy Practices that more specifically describes how we may use or disclose your protected health information.
Administrative Purposes. We may use Personal Information for administrative purposes, including measuring interest in Alto’s Services, developing new products and Services, ensuring internal quality control, verifying individual identity, preventing potentially prohibited or illegal activities, and enforcing our Terms and Conditions.
Marketing Alto Services. We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest to you, including new content or Services. We may provide these materials by phone, postal mail, email, or other means as permitted by law. You may opt out of Alto using your Personal Information for marketing purposes by following the opt-out instructions below.
Anonymous and Aggregated Information. We may use Personal Information and other information to create anonymized and aggregated information. Anonymized and aggregated information may be used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services, to help us optimally deliver our existing Services or develop new Services, conduct research or internal analysis, or any other legally permissible purpose. Anonymized or aggregated information is not Personal Information and is anonymized or aggregated in a way that is designed to prevent anyone from identifying you.
How Personal Information May Be Shared
Accounts with Multiple Users. When you are connected to an account with multiple users, we may share any information in your account with the other users connected to the same account.
Coupons, Vouchers, and Other Discounts. If you request coupons, vouchers, or other discounts, Alto may act as your agent to share data with manufacturers and their agents in order to request and obtain these coupons or voucher discounts on your behalf.
Service Providers. Your Personal Information may be accessed and used by our service providers who are working with us in connection with the operation of our Services. These service providers may have access to your Personal Information only to the extent necessary to perform services on our behalf and are obligated not to disclose that information or use it for any other purposes.
Payment Processors. Alto uses third-party payment processors. In order to process payments, these third-party processors may gather and transmit your data to and/or from financial institutions. By using our Services, you grant Alto and these payment processors the right, power, and authority to act on your behalf to access and transmit your Personal Information and financial information to and/or from the relevant financial institution.
To Protect Us or Others and as Required by Law. Alto may disclose your Personal Information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Alto or the site; (b) protect and defend the rights or property of Alto; and, (c) act under exigent circumstances to protect the rights, property, or personal safety of users of Alto, or the public.
Merger, Sale, or Other Asset Transfer. We may transfer and/or provide information about our users in connection with a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, or other situation where user information would be transferred as one of our business assets.
Alto may include links to social media and other third-party sites and mobile applications on its Services that are operated and controlled by third parties. We encourage you to review the privacy statements of websites you choose to link to from Alto so that you can understand how those websites collect, use and share your information. Alto is not responsible for the privacy statements or other content on websites outside of the Alto website.
“Do Not Track”
“Do Not Track” is a privacy preference that users can set in certain web browsers to signal to websites that you visit that you do not want to have your online activity tracked. We do not respond to or honor Do Not Track signals at this time.
Children Under Thirteen
Alto does not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, you must ask your parent or guardian for permission to use Alto’s Services. If you believe your child under the age of 13 has provided Alto with Personal Information, contact us as described below and we will promptly take steps to delete such information.
Alto and this website are based in the United States. Your Personal Information will be transferred to and maintained on computers located in the United States (or any other country where we operate) and processed there. By providing us with your information, you are accepting and agreeing to that transfer.
Data Retention and Deletion
Alto retains Personal Information for as long as you use our Services or as necessary to fulfill the purposes for which the information was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, comply with pharmacy regulations, enforce our agreements, and comply with applicable laws.
Security of your Personal Information
We employ administrative, physical and electronic measures designed to protect your information from unauthorized access. However, despite these efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. In the event that your Personal Information is compromised as a result of a breach of security, we will notify you, as required by applicable law.
We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. You can control communications such as emails and text messages by adjusting the preferences in your Alto account or following the instructions within those communications to unsubscribe or manage preferences. Users may opt out of receiving any or all communications from Alto by contacting us as described below.
Your Rights and Choices
Opt-Out & Unsubscribe
We respect your privacy and want to give you an opportunity to opt out of receiving announcements of certain information. You can control communications such as emails and text messages by adjusting the preferences in your Alto account or following the instructions within those communications to unsubscribe or manage preferences. Users may opt out of receiving any or all non-required communications from Alto by contacting us as described below.
Accessing and Deleting your Personal Information
If you would like to access Personal Information Alto holds about you or request that we delete Personal Information about you from our systems, please contact us as described below with a description of your request.
We will use reasonable efforts to honor your request. However, there may be circumstances where Alto is unable to provide access or delete your Personal Information, such as where the information is subject to legal privilege, would violate the privacy of another individual, we are required to keep it to evidence pharmacy activity, or it’s otherwise needed for auditing or other legal purposes. To protect your privacy, Alto will take reasonable steps to verify your identity before granting access or making changes to your Personal Information.
California Consumer Privacy Act (CCPA)The California Consumer Privacy Act of 2018 (“CCPA”), effective as of January 1, 2020, requires businesses that collect Personal Information of California residents to make certain disclosures regarding how they collect, use and disclose such information. Details regarding the Personal Information we collect, use, and disclose, and its sources, are included in Sections 2, 3 and 4 of this Policy. We do not “sell” your Personal Information as the term is defined under the CCPA.
The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), requires businesses that collect Personal Information of California residents to make certain disclosures regarding how they collect, use and disclose such information. The Personal Information we collect from patients is subject to the Health Insurance Portability and Accountability Act (“HIPAA”) and therefore exempt from CCPA and CPRA. For more information on your privacy choices and rights under HIPAA, please refer to our Notice of Privacy Practices. Alto employees, contractors, and business partners who reside in California should refer to our California Privacy Notice for details on how we collect, use, and disclose Personal Information.
The CCPA provides California residents the right to make the following requests regarding our collection and use of your Personal Information, subject to certain exceptions:
The right to request a copy of the Personal Information we collected, used, or disclosed for a business purpose during the preceding 12 months;
The right to request that we disclose Personal Information we collect, use and disclose; and
The right to request deletion of any Personal Information we have collected from you or maintained about you.
We will not discriminate against you for exercising any of your CCPA rights, such as offering you different pricing or products or services, or providing you with a different level or quality of products or services.
To exercise your CCPA rights, you can submit your request either to firstname.lastname@example.org or by calling 1 (800) 874-5881 and leaving a message for our Privacy Officer. To protect your privacy, Alto will take reasonable steps to verify your identity before reviewing and fulfilling such requests. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.
You may designate an authorized agent to make requests on your behalf to exercise your rights under the CCPA. We will require the authorized agent to provide a signed permission that shows the authorized agent has the authority to submit the request for a California consumer. We may also require the authorized agent to verify his/her own identity and registration to do business in California and we may confirm the agent’s authority with the California consumer about whom the request was made.
California “Shine the Light” Law
The California “Shine the Light” law (Civil Code Section § 1798.83) permits our customers that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us as described below.
If you have questions about privacy at Alto, including requests to opt out, unsubscribe, or access or delete your data, you can contact us:
Alto Pharmacy, LLC
645 Harrison Street, #200
San Francisco, California 94107