Privacy Policy

J. Knipper and Company, Inc., Privacy Policy

Knipper is committed to implementing appropriate policies, procedures, and information systems to preserve and safeguard your right to privacy. As part of this commitment, Knipper wants you to be fully aware of what happens to the personal information we collect from you. Accordingly, this Privacy Policy sets out the manner in which we will collect, use, disclose and otherwise manage your personal information. Specifically, this Privacy Policy explains:

• Why We Collect Information
• What Information is Collected
• How Information is Used
• With Whom Information is Shared
• Security of Personally Identifiable Information
• Opting-Out
• Correcting and Updating Information
• Changes in Privacy Policy
• How to Contact Us

WHY WE COLLECT INFORMATION

Knipper's business is to provide pharmaceutical marketing services to Pharmaceutical Companies, including manufacturers of over-the-counter and prescription pharmaceutical products ("OTC and Rx Products") and Health Care Organizations. Knipper's marketing services include: direct mail, DTC/DTP programs, kit design and assembly, web-ordering, e-survey programs, e-sampling and fulfillment, and telemarketing fulfillments, among others. In providing such services, the Pharmaceutical Companies, Health Care Organizations and/or Knipper may be required to obtain and use your personal information.

WHAT INFORMATION IS COLLECTED

In order to provide you with pharmaceutical marketing information such as information relating to OTC and Rx Products, we collect both Personally Identifiable Information (such as contact, financial and demographic information described below) and non-personally identifiable information such as "Traffic Data" (defined below) using the methods listed below.

In the course of providing pharmaceutical marketing services, Knipper collects Personally Identifiable Information you provide us when you:

• Request that we send you Discount Coupons for the purchase of OTC or Rx Products;
• Request that we send you Rebate Coupons for the purchase of OTC or Rx Products;
• Request that we send you a Rebate Check in connection with OTC or Rx Products which you have purchased;
• Request that we send you Trial Samples of OTC Products;
• Respond to one of our Surveys;
• Request that we send you Information about OTC or Rx Products;
• Participate in a Research Project which we coordinate on behalf of one of our Pharmaceutical Company clients; or
• Enroll in a Patient Assistance Program which we coordinate on behalf of one of our Pharmaceutical Company clients.

When you take any of the above actions we may collect Personally Identifiable Information from you such as your name, age, address, telephone number, e-mail address (and your password). We may also collect Protected Health Information from you such as information about your health conditions.

Personally Identifiable Information may also be collected when you register at Knipper's Website (www.Knipper.com) or provide your information to others such as Pharmaceutical Companies and Health Care Organizations, including by registering on their websites. Knipper's registration form may, from time to time, require you to give us basis contact information (such as your name, mailing and e-mail address) and some demographic information (such as your zip code, age and gender). The information requested by Knipper's registration form may change from time to time. Although additional demographic information may be requested at the time of registration, only information marked "required" is necessary for you to register on Knipper's Website and take advantage of the promotional offers made available thereon from time to time. With respect to your visits to our Website, we may automatically collect general anonymous information related to your use of that Website, such as the date and time you visit the Website and the pages you visit as well as collecting "cookie" information from your browser to identify your computer and provide us with a record of our visits to our Website (collectively, "Traffic Data"). The technology used to gather "cookie" information is provided by the Internet browser you use, and may be turned off by using your browser preference buttons.

At the present time, March 2008, Knipper does not collect PHI data from the Knipper website.

HOW THE INFORMATION IS USED

Knipper uses the Personally Identifiable Information or Protected Health Information that you provide to us for the purposes of: (a) providing you with information, discount coupons, rebate coupons, rebates, trial samples, prescription refill reminders and other marketing and non-marketing communications relating to OTC and/or Rx Products; (b) responding to your requests; and (c) generally communicating with you. Knipper only uses or discloses your Personally Identifiable Information or Protected Health Information as permitted by law or authorized by you.

Knipper engages in e-mail and direct mail marketing on behalf of Pharmaceutical Companies and Health Care Organizations. E-mail or direct mail address lists for these marketing campaigns are compiled from information provided by you as set out above and/or based upon information gathered by Pharmaceutical Companies or Health Care Organizations. In order to receive an e-mail message or a direct mail communication that is part of a marketing campaign created by Knipper on behalf of a Pharmaceutical Company or Health Care Organization, you chose to be included on an e-mail or direct mail address list or chose to receive e-mail or such direct mail communication from us. You may choose not to receive future e-mail or direct mail communications from us (see Opt-Out Policy below).

The Traffic Data helps us to understand how our Website is used (e.g., which pages or sections are most popular and when the peak activity times occur) and to assist us in planning for future improvements to the Website to better meet your needs.

WITH WHOM INFORMATION IS SHARED

Knipper will not share your Personally Identifiable Information, including your Protected Health Information except as authorized by you, permitted by applicable law or described below.

Knipper may share your Personally Identifiable Information with Pharmaceutical Companies or Health Care Organizations in order to customize marketing and non-marketing communications and provide you with information, discount coupons, rebate coupons, rebates, trial samples and prescription refill reminders relating to OTC and/or Rx Products in which you are interested.

Knipper may share your Personally Identifiable Information, including your Protected Health Information, on a confidential basis with third party service providers that we retain from time to time to perform work on our behalf. These third party service providers are not authorized to use or disclose this information for any purpose other than to perform services on Knipper's behalf.

Knipper may disclose your Personally Identifiable Information or Protected Health Information when it believes the disclosure is appropriate to comply with applicable law; or protect the rights, property, or safety of Knipper, those persons who disclose their Personally Identifiable Information Protected Health Information to us, or others. We must provide your Personally Identifiable Information, including your Protected Health Information: (a) in response to a search warrant or other legally valid enquiry or order; (b) to an investigative body; (c) in the case of a breach of an agreement or contravention of law; or (d) as otherwise required by law.

The Knipper Website may include links to third party websites. These linked sites have separate and independent privacy policies. Knipper has no control over such sites and therefore has no responsibility or liability for the manner in which the organizations which operate such linked sites may collect, use or disclose and otherwise treat your personal information.

SECURITY OF PERSONAL INFORMATION

Knipper is committed to implementing appropriate policies, procedures to maintain your personal information in secure data storage to safeguard it from unauthorized access, use or disclosure and maintain the strict confidentiality of all personal information collected. Knipper will only disclose such information to the Pharmaceutical Companies or Health Care Organizations who are our clients, Knipper employees and third party service providers who require such information for the purposes set out above. We will only keep your personal information for as long as it remains necessary or relevant for the purposes stated above or as otherwise required by law.

OPTING - OUT

If Knipper has collected your Personally Identifiable Information or Protected Health Information, Knipper will process your election to opt-out. If however, someone other than Knipper has collected that information, you must contact that other person to opt-out. If you would like to opt-out, that is to withdraw your authorization to the use and/or disclosure of your Personally Identifiable Information or Protected Health Information which Knipper has collected, you may do so at any time by notifying us of your decision to opt-out. You may provide such notification by writing to us at J. Knipper and Company, Inc., Attention: Privacy Officer, One Healthcare Way, Lakewood, New Jersey 08701. Please be certain to include the name of the program in question.

CORRECTING OR UPDATING INFORMATION

If you would like to correct or update any of your Personally Identifiable Information or Protected Health Information we have in our possession, please write to us at J. Knipper and Company, Inc., Attention: Privacy Officer, One Healthcare Way, Lakewood, New Jersey 08701. Please be certain to include the name of the program in question.

CHANGES IN PRIVACY POLICY

Knipper reserves the right, at any time and without notice, to add to, update, change, modify or revise this Privacy Policy by posting such addition, update, change, modification or revision on its Website at www.Knipper.com. Any such addition, update, change, modification or revision will be effective immediately upon posting on the Website. You will have a choice and may notify us if you do not wish us to use your information in this different manner (See "Opting-Out"). Knipper may use personal information in accordance with the version of the Privacy Policy that is in effect from time to time.

HOW TO CONTACT US

If you have any inquiries or comments about this Privacy Policy, please contact us at 1-888-564-7737 or write to us at J. Knipper and Company, Inc., Attention: Privacy Officer, One Healthcare Way, Lakewood, New Jersey 08701.