Why We Collect Information
Knipper provides marketing services to the pharmaceutical, biotechnology and life sciences industries, and to other healthcare related organizations and businesses, including manufacturers of over-the-counter medications, and prescription drug products (“OTC and Rx Products”). Knipper’s marketing services include direct mail, direct-to-consumer and direct-to-practitioner programs, kit design and assembly, web-ordering, e-survey programs, e-sampling and fulfillment, and telemarketing services and fulfillment. In connection with these services, you may provide to Knipper certain personal information in order to participate in our services, or Knipper may collect certain non-personal information from you upon visiting our website. Knipper may use your information to analyze user preferences so that we can better design services for you, such as customized offers to appeal to our users’ personal and/or professional interests.
What Information is Collected
In connection with programs such as those listed below, 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).
- Discount Coupons or cards requested for the purchase of OTC or Rx Products;
- Rebate Coupons or cards requested for the purchase of OTC or Rx Products;
- Rebate Checks or cards in connection with OTC or Rx Products which you have purchased;
- Trial Samples requested for OTC Products;
- Survey requests and responses submitted by you;
- Information requested by you about OTC or Rx Products;
- Your participation in a Research Project which we coordinate on behalf of one of our Pharmaceutical Company clients; or
- Enrollment in Patient Assistance Programs which we coordinate on behalf of one of our Pharmaceutical Company clients.
Any of the above actions may result in our collection of your Personally Identifiable Information such as your name, age, address, telephone number, e-mail address, and any applicable enrollment or registration passwords. We may also collect Protected Health Information provided by you as applicable to any of the above programs. In addition, Knipper may come into possession of your Personal Identifiable Information or your Protected Health Information when you provide it to our business partners such as Pharmaceutical Companies and Health Care Organizations, when you register or enroll on their websites for offers and programs that Knipper has been contracted to fulfill on their behalf.
Personally Identifiable Information may also be collected when you register at Knipper’s Website (www.Knipper.com). Knipper’s registration form may, from time to time, require you to give us basic 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 our website in order to take advantage of the promotional offers in which you may be interested. 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.
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 as 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 you may 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 at any time by following the Opt-Out Policy below.
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, as permitted by applicable law or as 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 have expressed an interest by contacting us or our business partners.
Knipper may share your Personally Identifiable Information, including your Protected Health Information, on a confidential basis with third party service providers with whom we have a business relationship 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 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.
Knipper may be called upon to release Personally Identifiable Information or Protected Health Information in response to a court order, subpoena, search warrant, law or upon request of a regulatory or investigative agency. Knipper’s cooperation in responding to such requests includes notice of the sensitivity of the information that is being sought or provided. Knipper also reserves the right to cooperate with law enforcement authorities in the investigation and prosecution of users who violate our rules or who otherwise engage in harmful or illegal behavior via our websites.
Security of Personal Information
Knipper is committed to ensuring the security of the information you provide to us. Our success in designing useful products and services depends on your willingness to participate in our programs. Knipper’s business methods include strict policies on the storage, transmission and use of data that includes personal information. Our standard operating procedures are designed to secure such information in accordance with applicable law and industry standards. Notwithstanding Knipper’s efforts, you should be aware that there is some risk of loss, misuse or alteration of your information by unauthorized third parties engaging in illegal and deceptive practices that may find a way to penetrate our data security measures.
If Knipper has collected your Personally Identifiable Information or Protected Health Information and you are no longer interested in receiving our services, you may withdraw your authorization at any time. If you would like to opt-out, you may do so by providing written notice to us at J. Knipper and Company, Inc., Attention: Privacy Officer, One Healthcare Way, Lakewood, New Jersey 08701. Knipper will process your election to opt-out as soon as possible upon receipt. Please be sure to include the name of the program, product or service from which you wish to withdraw. Also note that if some other organization or entity collected that information, you must contact that entity directly with your opt-out request.
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, product or service in question.
How to Contact Us
J. Knipper and Company, Inc.,
Attention: Privacy Officer
One Healthcare Way
Lakewood, New Jersey 08701.
TYPES OF PERSONAL INFORMATION COLLECTED BY KNIPPER BY CATEGORY
|CCPA Category of Personal Information||Collected by Knipper in the last 12 months|
|i. Identifier||Name, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, and other similar identifiers|
|ii. Customer Records||Name, signature, address, telephone number, education, employment|
|iii. Protected classification characteristics under California or federal law.||not collected|
|iv. Commercial||Records of products or services ordered or purchased or those which you have access to order or purchase.|
|v. Biometric||not collected|
|vi. Internet or network activity.||Information regarding a consumer’s interaction with our websites, application, or advertisement, passwords and pins created to access our websites|
|vii. Geolocation data||Geographic location based on URL|
|viii. Sensory data.||not collected|
|ix. Professional or employment-related information.||DEA#s, SLN#s, SAN #s; employee ID#; healthcare provider designations, and/or specialties; employee territories, employers, managers|
|x. Non-public education information||not collected|
|xi. Inferences||Knipper may make certain inferences from individual or combined pieces of Information in (i) –(x)|
|Personal Information does not include:||Personal information does not include: Publicly available information from government records; De-identified or aggregated consumer information; health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or similar state statutes; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.|
DISCLOSURES OF PERSONAL INFORMATION IN LAST 12 MONTHS
- Knipper does not collect information from minors.
- Knipper does not sell any information referenced above.
- In the preceding twelve (12) months, Knipper has not sold any information referenced above.
- In the preceding twelve (12) months, Knipper has disclosed the following categories of personal information for a business purpose: (i), (ii), (iv), (vi), (vii), (ix), (xi).
- Knipper only discloses your personal information as required by law or for a business purpose to our affiliates, service providers and third parties where you, your employer, or your agent(s), have authorized that disclosure.
YOUR RIGHTS UNDER THE CCPA
CCPA ACCESS RIGHTS
You have the right to request that Knipper disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once Knipper receives and confirms your verifiable consumer request, Knipper will disclose to you:
- The categories of Personal Information that Knipper collected about you.
- The categories of sources for the Personal Information that Knipper collected about you.
- Knipper’s business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom Knipper shared that Personal Information.
- The specific pieces of Personal Information Knipper collected about you (also called a data portability request).
- If Knipper disclosed your Personal Information for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
CCPA DELETION RIGHTS
You have the right to request that Knipper delete your Personal Information, subject to certain exceptions. Once Knipper receives and confirms your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
Knipper may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which Knipper collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise a right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
CCPA PORTABILITY RIGHTS
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us at 1-888-564-7737 or email@example.com. 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 related 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 Knipper to reasonably verify you are the person about whom Knipper collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Knipper cannot respond to your request or provide you with Personal Information if Knipper cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Knipper will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
CCPA REQUESTS, RESPONSES, AND TIMING
Knipper will try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If Knipper requires more time, Knipper will inform you of the reason and extension period in writing. Knipper will deliver our written response by mail or electronically, at your option. Any disclosures Knipper provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response Knipper provides will also explain the reasons Knipper cannot comply with a request, if applicable. For data portability requests, Knipper will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. Knipper does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Knipper determines that the request warrants a fee, Knipper will tell you why Knipper made that decision and provide you with a cost estimate before completing your request.