Privacy
StrongRoom AI is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.
STRONGROOM AI INC. US PRIVACY POLICY
1. ABOUT THIS POLICY
1.1 This Privacy Policy (“Policy”) applies to StrongRoom AI Inc. (“StrongRoom AI”, “we”, “our” or “us”), and describes how StrongRoom AI collects, discloses, handles and protects the privacy of individuals with whom we interact (“you”).
1.2 StrongRoom AI provides technology to its customers (including pharmacies, care facilities and hospitals) that uses personal (including patient health) data to streamline services, including managing patient medication efficiently and transparently.
1.3 We are committed to protecting privacy and understand the importance of protecting personal information that we collect or that is inputted into our services.
1.4 This Policy outlines the types of personal information that we may collect from you or that you may provide to us, the purposes for which we collect it, to whom we disclose it, how we hold and keep it secure, and your rights in relation to your personal information.
1.5 We handle personal information in accordance with this Policy and applicable legislation, including HIPAA, CCPA/CPRA and other relevant US privacy laws.
1.6 In this Policy, personal information means any information or opinion about an identified individual or an individual who is reasonably identifiable, whether true or not. It does not include information that is de-identified.
1.7 We may change this Privacy Policy from time to time by publishing changes on our website at www.strongroom.ai/en-us/ (Site).
2. INFORMATION WE COLLECT
2.1 StrongRoom AI may collect several types of information including personal information from and about users of our Site and services (including our customers’ representatives, employees and contractors), as well as individuals with whom we otherwise interact. The types of personal information we collect depends on the dealings we have with an individual. For example:
a) For users of our Site:
(i) identifiers (eg name, alias, email address, phone number, company name, unique personal identifier, internet protocol address, referral information, other similar identifiers);
(ii) commercial information (eg company name, position, business contact details, other similar information);
(iii) internet or other electronic network activity information (eg internet protocol address, browser type, cookies used for identification, and information regarding a consumer’s interaction with the Site);
b) For our customers’ representatives (including employees and contractors):
(i) your name, employer, position and business contact details;
(ii) if you elect to enable the functionality, biometric data (ie facial & fingerprints) for use of our software; and
(iii) your preferences;
2.2 For job applicants: StrongRoom AI may also collect the following categories of personal information in connection with your employment or application to work for us, or, in the case of contractors, in connection with the services you perform for us:
a) Identifiers (e.g., name, address, email address, birthdate, age, social security number, driver’s license number, passport number);
b) Personal records (e.g., telephone number; signature; employment-related information such as date of hire, title and compensation; education information; account number; tax information; medical and other health information; health insurance information; criminal background information; beneficiary dependent information; travel and emergency contact information; work eligibility information);
c) Characteristics and demographic information (e.g., sex, gender, marital status, veteran status, race, ethnicity, disability);
d) Professional or employment information (e.g., resume, cover letter, employment history, background check forms, references);
e) Internet and device usage information (e.g., IP address, internet browsing history, telephone usage and recordings, device geolocation data, email and message content);
f) Time clock data, images, video and audio recordings, and biometric data; and
g) Inferences from personal information collected (e.g., interview notes and impressions, performance reviews).
2.3 StrongRoom AI may also collect personal information inputted into our software and services by our customers (including about their patients, suppliers and prescribers). Some of the information inputted into the software by our customers may include protected health information (“PHI”) about patients. To the extent applicable, all PHI received by Strong Room AI from customers who are covered entities under HIPAA shall be subject to the terms of the Business Associate Agreement (BAA) between the relevant covered
entity and StrongRoom AI.
3. WAYS WE COLLECT YOUR PERSONAL INFORMATION
3.1 We may collect personal information from or about you in different ways depending on your dealings with us, including:
a) from you directly when you interact with us, e.g., from our discussions with you, when you complete a form, from your emails or from your interaction with our Site;
b) through third parties with whom we interact in order to provide our services; and
c) from publicly available sources, including social media.
3.2 If you apply for a job or contract position with us, we may also collect personal information about you from third parties and publicly available sources, including:
a) recruiters;
b) government departments to verify your entitlement to work or other relevant location;
c) relevant agencies to obtain your criminal history record;
d) academic institutions;
e) your current or previous employers; or
f) your referees.
4. PURPOSES FOR WHICH WE COLLECT AND USE PERSONAL INFORMATION
4.1 We collect and use your personal information for the following purposes:
a) for the specific purpose for which it was volunteered (for example, to contact us, including to utilise or sample/demo our services);
b) to provide and update our services;
c) to manage and conduct our business;
d) to offer or promote our products and services;
e) to obtain feedback;
f) to help us manage, develop and enhance our services, including our Site and applications; and
g) to comply with our legal obligations, resolve any disputes, and enforce our agreements and rights with third parties.
4.2 For job applicants: We may use your personal information (in connection to job applicants as described above) for one or more of the following business purposes:
a) Performing services and providing benefits (e.g., providing human resources services, verifying your information, processing payroll or expense reimbursements, providing and processing benefits and providing other similar services);
b) Compliance with federal and state laws, including maintaining and reporting certain records and information;
c) Hiring, firing, and managing and reviewing personnel job duties and performance;
d) Protecting the health and safety of our personnel, clients, guests, and the general public;
e) Security (e.g., detecting security incidents, protecting against fraudulent or illegal activity, authenticating your identity and providing access to our devices, facilities and data); or
f) Workplace monitoring (e.g., CCTV and telephone recording, email and internet usage, device monitoring, time clock recording).
4.3 With our customer’s consent, we may also de-identify personal information for our business purposes, including:
a) Conducting data analytics activities about our services;
b) Generating insights and benchmarks for our customers;
c) Product development and research;
d) Marketing and improvement of our services; and
e) Training of our algorithms and our artificial intelligence models.
5. DIRECT MARKETING
5.1 We may use your personal information to identify a product or service that you may be interested in. We may, with your consent, use the personal information we have collected about you to contact you from time to time whether by email to tell you about new products or services and special offers that we believe may be of interest to you.
5.2 You may choose to opt out of receiving future marketing or promotional email messages from us. Each such email (excluding non-promotional communications, such as those responding to your specific inquiries or related to your relationship with us) sent by us contains an “unsubscribe,” “opt- out”, or similar link with instructions on how to remove yourself from the applicable email list. Additionally, we may always email you in response to your correspondence or in connection with any other transactions you have with us.
6. SHARING YOUR PERSONAL INFORMATION
6.1 We do not sell or share your personal information to third parties, or disclose your personal information to third parties for their marketing purposes, except as set forth herein. In the course of providing our products and services, we may transfer or subprocess your personal information (which does not include PHI) as follows:
a) to our service providers (such as our customer support specialists, email campaign providers, payment processors, etc.);
b) organisations with whom we contract who provide services to us (such as IT vendors);
c) anyone to whom part of all of our assets or businesses are transferred or sold;
d) our affiliate and subsidiary companies under common ownership, management or control with us;
e) our professional advisers, including lawyers, accountants and auditors;
f) as required by law or legal proceeding or to protect our or others’ legal rights;
g) in connection with an acquisition, merger, sale, or other transfer of all or any portion of our business; and
h) government agencies, regulatory bodies, law enforcement agencies or other similar entities.
6.2 All transfers and subprocessing of PHI will be governed by our BAA with our customers.
6.3 We have disclosed for a business purpose to our service providers the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer:
· Identifiers (e.g., name, alias, email address, phone number, company name, unique personal identifiers, internet protocol address, referral information, other similar identifiers)
· Commercial information (e.g., company name, position, business contact details, other similar information)
· Internet or other electronic network activity information (e.g., internet protocol address, browser type, cookies used for identification, and information regarding a consumer’s interaction with the Site).
7. COOKIES
7.1 In order to personalize and enhance your experience on our Site, we also may collect information through “cookies.” Cookies are small strings of text sent by our Site to your browser and then stored by your browser on your computer’s hard drive. Our cookies allow us to not only personalize your experience on our Site, make your visit more convenient, and understand how you and others are using our Site so we can improve your experience on the Site. We use cookies to identify repeat visitors to our Site and to determine the paths visitors take on our Site. We also use cookies to determine whether you visited our Site from a particular Internet link or advertisement.
7.2 Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Site. Just like any other usage information we collect, this information allows us to improve the Site and customize your online experience, and otherwise as described in this Privacy Policy.
7.3 Additionally, we use certain advertisement networks (such as Microsoft Advertising Universal Event Tracking, Google Analytics, Facebook Pixel, LinkedIn Insight, Simpli.fi Ad Tracking) that use retargeting cookies to collect certain information about you (including the pages and content you view, the date and time of such views, and location information associated with your IP
address).
7.4 To opt-out or adjust your preferences for retargeting cookies that may collect information about your online activity while you are using the Site, please click here Cookie Policy.
8. THIRD-PARTY ANALYTICS SERVICES
8.1 Additionally, we use Google Analytics to better understand the behavior of visitors to our Site. This includes anonymized data associated with your IP
address, such as pages viewed on the Site, length of time on the Site, browser used to access the sites, and device used to access the Sites. The information collected does not personally or directly identify you or your street address. To learn more about how Google uses data when you visit our Site please visit: How Google uses information from sites or apps that use our services –
Privacy & Terms – Google. You can opt out from the use of Google Analytics by following the instructed provided at: Google Analytics Opt-out Browser Add-on Download Page.
9. DATA RETENTION
9.1 We will retain your personal information and non-personal information for as long as it is reasonably necessary to fulfill the purpose for which it was given. Different retention periods apply for different types of personal information based on the purpose for which it was gathered.
9.2 We reserve the right to dispose of or delete any or all such personal information or non-personal information at any time (including prior to any specific retention timeframe we may communicate), except as set forth in any other agreement or document executed by both you and us concerning the same or as required by law.
10. SECURITY AND STORAGE
10.1 We store your personal information electronically. Electronic information is stored by our third party storage providers.
10.2 We take reasonable and appropriate steps (including organizational and technological measures) to protect your personal information from misuse, interference and loss, as well as from unauthorised access, modification or disclosure. While our security measures are intended to protect your personal information, the complete security of any transmission over the public internet cannot be guaranteed.
11. STATE PRIVACY RIGHTS
11.1 You may be entitled the following privacy rights listed below based on various state privacy laws, including if you are a resident of California, Colorado, Connecticut, Utah and Virginia:
a) The rights to know/access. You may have the right to request to access or know (i) the specific pieces of personal information we have about you; (ii) the categories of personal information we have collected about you; (iii) the categories of sources from which that personal information was collected; (iv) the categories of personal information we have sold or disclosed; (v) the categories of third parties to whom your personal information was sole or disclosed; and (vi) the purposes for collecting and selling your personal information. Generally:
– The Company has collected the categories of personal information detailed in the section titled “Information We Collect” above.
– The Company has disclosed the categories of personal information detailed in the section titled “Sharing Personal Information” above.
b) The right to correction. You may have the right to request that we correct the personal information that we have collected or maintain about you.
c) The right to deletion. You may have the right to request that we delete the personal information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected. If we deny your request for deletion, we will let you know the reason why.
d) The right to restrict or opt out of the sale of your personal information. You may have the right to opt out of the sale of your personal information. We do not sell your personal information. If this changes, we will update our privacy policy accordingly.
e) The right to equal service. If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our services.
You may request your right to know and your right to deletion free of charge up to two (2) times in any twelve (12) month period.
To exercise the rights described above, please contact us as follows:
Email: office@strongroom.ai (please use “Consumer Privacy” in the subject line)
Phone: +1 (215) 315-3296
Mail: 3675 Market Street, Suite 200, Philadelphia, PA 19104
We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request.
12. EXERCISING YOUR RIGHTS
12.1 You can exercise your rights by contacting us using the details below set out in this Policy. We will respond to you within a reasonable period of time to acknowledge your request and inform you of the next steps we will take in dealing with your request.
13. CHILDREN’S DATA
13.1 The Site is not directed at or intended to be used by children, and StrongRoom AI will not intentionally collect or maintain personal information about anyone under the age of 16, except for information provided by the relevant parent(s) or guardian(s). If we discover that we have collected any other personal information about anyone under the age of 16, we will take reasonable steps to promptly delete such information from our systems.
14. CONTACT US
14.1 If you have a question or comment regarding this Policy or wish to make a complaint or exercise your privacy rights, please address your correspondence to our Human Resources Manager at office@strongroom.ai.