Privacy Policy

MEDTRAKR.COM PRIVACY POLICY

Introduction

Acceptance and Use

This privacy policy covers MedTrakr and its subsidiaries including (collectively, " MedTrakr.com," "we" "us" or "our"). By using MedTrakr website and web application, you signify acceptance to the terms of this Privacy Policy. Where your acceptance via clicking on [ACCEPT] when this policy is displayed to you on the site, is considered as your official consent to process your personal information, your consent to the collection, use, and disclosure of your personal information as described further below. We may request you to provide additional disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.

If you do not agree with or are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of MedTrakr website and web application and its related services.

Who We Are?

MedTrakr.com provides a web application that connects pharmacy, users and drivers. We enable an easy-to-use platform interface for pharmacy owners and drivers to register and list their services and medication on the platform. We also provide a user an opportunity to search for and place an order for a medication of their choice which will be delivered by registered and approved drivers of the platform.

Data Protection Principles

We collect, process, and use personal data (under the definitions of The United Kingdom Data Protection Act 1998 (c. 29) and the required European Union GDPR Regulation to provide our services. Personal data means any information that enables us to identify you, directly or indirectly, such as name, email, address, telephone number, any form of identification number, or one or more factors specific to you or your beneficiary's identity.

We are committed to complying with applicable data protection laws and will ensure that personal data is:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only if necessary, for the purposes we have told you about.
• Kept securely.

The information we collect and how we use it

MedTrakr ("MedTrakr" the "Company," "we," "us," and "our”) collects several types of information from and about users of our Services, including:

• Your Personal Information("PI") - Personal Information is the information that can be associated with a specific person and could be used to identify that specific person whether from that data, or from the data and other information that we have or is likely to have access to. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.
• Information about your internet connection, the equipment you use to access our Services and your usage details.

We collect this information:

• directly from you when you provide it to us; and/or
• automatically as you navigate through our Services (information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies).

Information You Provide to Us

The information we collect on or through our Services may include:

• Your account information: Your full name, email address, postal code, password and other information you may provide with your account, such as your gender, mobile phone number and website. Your profile picture that will be publicly displayed as part of your account profile. You may optionally provide us with this information through third-party sign-in services such as Facebook and Google Plus. In such cases, we fetch and store whatever information is made available to us by you through these sign-in services.
• Your preferences: Your preferences and settings such as time zone and language.
• Your searches and other activities: The search terms you have looked up and results you selected.
• Your browsing information: How long you used our Services, and which features you used; the ads you clicked on.
• Your communications: Communications between you and other users or merchants through our Services; your participation in a survey, poll, sweepstakes, contest or promotion scheme; your request for certain features (e.g., newsletters, updates or other products); your communication with us about employment opportunities posted to the services.
• Your transactional information: If you make purchases through our Services, we may collect and store information about you to process your requests and automatically complete forms for future transactions, including (but not limited to) your phone number, address, email, billing information and credit or payment card information. This information may be shared with third-parties which assist in processing and fulfilling your requests, including PCI compliant payment gateway processors. When you submit credit or payment card information, we encrypt the information using industry standard technologies, as further described below under "Payment Card Information." If you write reviews about businesses with which you conduct transactions through our Services, we may publicly display information that you transacted with those businesses.
• We use the information you provide to us to enhance the functionality and improve the quality of our Services, and to personalize your experience while using our Services. We also use this information to display relevant advertising, provide support to you, communicate with you, and comply with our legal obligations.

Non-Personal Information

Non-personal information refers to information that, by itself, does not identify you as a specific individual (e.g., demographic information or web site visitations). MedTrakr may collect non-personal information through any of the methods discussed above as well as automatically through use of industry standard technologies described further below.

UK and EU Cookie Law

The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011; Cookies is a small text file placed on your computer by this Website and web application when you visit certain parts of the Website and web application and/or when you use certain features of the Website and web application.

We use cookies and similar technologies for purposes such as:

• Authenticating users
• Remembering user preferences and settings
• Determining the popularity of content
• Delivering and measuring the effectiveness of advertising campaigns
• Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

Details of the cookies used by this Website and web application are set out in the (Cookies policy page).

Third Party-Payment Processors

We use third-party payment processors to process payments via the MedTrakr website. For security purposes, MedTrakr does not collect or receive any sensitive payment information, such as your complete card number or authentication data. For additional Information about how your payment information is processed and stored, we advise you to review the applicable payment processor's Privacy Policy.

Information Collected Through Technology

While you are able to visit the MedTrakr site and remain anonymous, MedTrakr or its third-party service providers may still collect non-personal information about your use of the MedTrakr materials (e.g. Your internet browser, operating system, I P address, connection speed, and the domain name of your internet service provider). Such information may be gathered by the following methods:

1. Cookies. Cookies, including local shared objects, are small pieces of information that are stored by your browser on your device’s hard drive which work by assigning to your computer a unique number that has no meaning outside of the MedTrakr site. Cookies do not generally contain any personal information. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. Not accepting cookies may make certain features of the MedTrakr materials unavailable to you.
2. IP address. You may visit many areas of the MedTrakr site anonymously without the need to become a registered user. Even in such cases, MedTrakr may collect ip addresses automatically. An IP address is a number that is automatically assigned to your computer whenever you begin services with an internet services provider. Each time you access the MedTrakr site and each time you request one of MedTrakr’ pages, the server logs your ip address.
3. Beacons. Beacons are small pieces of data that are embedded in web pages and e-mails. MedTrakr may use these technical methods in html e-mails that MedTrakr sends to users to determine whether they have opened those e-mails and/or clicked on links in those e-mails. The information from use of these technical methods may be collected in a form that constitutes personal information.
4. Tracking content usage. If you use the MedTrakr services and you post audio visual materials including, without limitation, text, logos, artwork, graphics, pictures, advertisements, sound and other related intellectual property contained in such materials (collectively, “content”) to your app site or to a third-party site, MedTrakr tracks and captures non-personal information associated with user accounts and the use of content.

How We Use Your Data

For purposes of the General Data Protection Regulation (GDPR), MedTrakr is the "data processer". We will retain any Data you submit for a minimum of 12 months or the length of our services. Your Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website and web application. Specifically, Data may be used by us for the following reasons:

1. We also use the data we collect:
2. To enhance the safety and security of our users and services
3. For customer support
4. For research and development
5. To enable communications between users
6. To send marketing and non-marketing communications to users
7. In connection with legal proceedings

MedTrakr does not sell or share user personal data with third parties for their direct marketing, except with users’ consent. In each case, in accordance with this privacy policy. We may use your data for the following purposes:

• We use your data to verify you when you access your account.
• Create and update users’ accounts.
• Verify drivers’ and Pharmacy persons’ identity, background history, and Authenticity.
• Enable order placement, order process, deliveries, and other services.
• Offer, process, or facilitate payments for our services.
• Track and share the progress of deliveries.
• We use your data when we communicate with you (e.g., when we respond to a customer support or other inquiry).
• We use your data to understand how our services are being used and how we can improve them. In general, we analyze aggregated data, rather than specific user data. We may, however, need to analyze a specific case to address a specific problem (e.g., a bug that affects only a few accounts).
• We use your data to personalize the service to you. This may include remembering your preferences for language or volume or displaying app that you might enjoy, based upon your viewing choices.
• We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of MedTrakr Services.
• We use your data to display ads and send you offers. We may also use your data in delivering third-party advertisements to you. This may include "targeted ads" based upon your activities.
• We use your data where we are legally required to do so. For example, we may need to gather your data to respond to a subpoena or court order.
• We process your personal information to better understand the way you use and interact with MedTrakr's Services. In addition, we use such information to customize, measure, and improve features and the content and layout of our site and applications, and to develop new services.

We may use algorithms and other automated means to implement any of the above.

Remarketing On the website and web application

If you have provided your consent by accepting Targeting Cookies on the site, we may use Google AdWords (remarketing and Similar Audience features) and Facebook Ads. You can review the MedTrakr cookie policy which includes details on how to customize your cookie settings.

Google AdWords

Google AdWords enables Google, using cookies, to identify the fact that you have visited the site, to identify aspects of your usage of the App and combine that with what it knows about your usage of another site in the Google ad network. We use these services to advertise to visitors of Google ad network Apps who have previously visited our site or who Google deems to have shared interests with visitors of our site. Google’s collection and use of your personal data is covered by the Google privacy policy. You can set preferences for how Google advertises to you using the Google Ad Preferences page.

With Whom We Share Your Data

Some of our products, services, and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

• With your consent: we may share your data with third parties where we have obtained your express consent to do so. You may revoke these consents.
• Authorized vendors: we may share your data with third-party vendors that help us operate our services, process payments, and comply with your instructions and our contractual obligations. This includes payment processors, content delivery networks (cdns), cloud-based hosting services, monitoring services, email service providers, quality assurance and testing vendors, fraud and abuse prevention vendors, customer relations management (crm) vendors
• Advertising: we may share your data with advertising companies to display relevant ads to you. Unless you expressly agree, we will not share or sell your name, email address, or physical address with such persons.
• With Service Providers: We may share personal Information with delivery drivers, consultants, payment processors, and other service providers that provide us with specific services and unique process information on our behalf. These services may include providing customer support, performing business and sales analysis, supporting our website functionality, facilitating payment processing, and supporting contests, surveys, and other features offered on our Platform. These service providers are not permitted to use your personal Information for any other purpose, and their use of such personal data will be subject to appropriate confidentiality and security measures.
• Analytics: we may share your data with persons who provide analytics showing how customers are using our services.
• Affiliates and advisors: we may share your data with our affiliates company, and our auditors and advisors for planning, financial reporting, accounting, auditing, tax filings, and legal compliance. Unless you expressly agree, we will not share your data with our parent or any affiliate for other purposes, such as direct marketing.
• Certain legal situations: we may share your data where we believe disclosure is necessary to comply with a legal obligation or in connection with a corporate transaction.
• Aggregated or anonymized information: we may publicly disclose non-personal aggregated or anonymized information such as our number of visitors and registered users.

Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and devices. DNT is a way for users to inform website and web applications and services that they do not want certain information about their webpage visits collected over time and across website and web applications or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Interest-Based Advertising Technologies

As noted above, you may limit advertising tracking using advertising identifiers through your browser privacy settings.

The online advertising industry also provides website and web applications from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and learn more about targeted advertising and consumer choice and privacy, at networkadvertising.org/managing/opt_out.asp, or youronlinechoices.eu/ and aboutads.info/choices/

Data Retention

We retain your data for as long as you have an account. When you close an account, we will delete your personal information. We may retain logs of automatically collected information (for internal analytics); your email address; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.

If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.

EEA and Non-EEA Data Subjects

Legal Bases for Processing your Information:

For individuals who are in the European Economic Area, United Kingdom or Switzerland (collectively “EEA Residents”) at the time their personal data is collected, we rely on legal bases for processing your information under Article 6 of the EU General Data Protection Regulation (“GDPR”). We generally only process your data where we are legally required to, where the processing is necessary to perform any contracts, we entered with you (or to take steps at your request prior to entering a contract with you), for our legitimate interests to operate our business or to protect MedTrakr.com website and web application or your, property, rights, or safety, or where we have obtained your consent to do so.

Your Data Protection Rights

We enable you to make numerous choices about your data: Below is the following data protection rights you have when you use our services.

• You may choose not to provide us with certain Information.
• Suppose you wish to access, correct, update or request deletion of your personal Information. In that case, you can do so at any time by contacting us through the customer services portal or at the Information provided at the bottom of this Privacy Policy.
• If you request access to your data, we will confirm whether we hold your Information and provide you with a copy, explaining how we process it and why, how long we store it for, and your rights associated with it.
• If you request the deletion of your personal Information, we will erase it. Please note that we will need to retain any information that we require to fulfill our legal obligations or establish, exercise, or defend a legal claim.
• You can object to your personal information processing, ask us to restrict the processing of your personal Information, or request portability of your personal Information. Again, you can exercise these rights by contacting us through the customer services portal or at the Information provided at the bottom of this Privacy Policy.
• You have the right to opt-out of email marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you.
• Opting out Of Messages from Us: To opt-out of any future promotional messages from us, you should unsubscribe in the body of the promotional message sent to you (found at the bottom of the email) or send an unsubscribe request to us. We will process your request within a reasonable time after receipt.
• Similarly, if we have collected and processed your personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted before your withdrawal, nor will it affect the processing of your personal Information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal Information. Please contact us for more Information, and we will send you a link or our data protection officer address.
• The easiest way to submit your request to us is through our Customer support email found at the bottom of this Privacy Policy. We respond to all requests we receive from individuals wishing to exercise their data protection rights under applicable data protection laws.

Legal Bases for Processing (For EEA Users):

If you are an individual in the European economic area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the services you use and how you use them. This means we collect and use your information only where:

• We need it to provide you the services, including to operate the services, provide customer support and personalized features and to protect the safety and security of the services.
• It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests.
• You give us consent to do so for a specific purpose; or
• We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, and this may mean no longer using the services

Third-Party Site and Links

MedTrakr contents may contain links to third parties who may collect personal information and non-personal information directly from you. Additionally, MedTrakr may use third parties to provide components of the MedTrakr contents. In either case, such third parties may have separate privacy policies and data collection practices, independent of MedTrakr. MedTerakr: (a) has no responsibility or liability for these independent policies or actions; (b) is not responsible for the privacy practices or the content of such site; and (c) does not make any warranties or representations about the contents, products or services offered on such App or the security of any information you provide to them

Data Processer and Transfer

MedTrakr are the data processer for the personal data collected in connection with use of MedTrakr’s services in the European Economic Area and the United Kingdom. MedTrakr is also the data processor for the personal data collected in connection with use of MedTrakr’s services anywhere else.

MedTrakr operates, and processes data, globally. We may also transfer data to countries other than the one where our users live or use MedTrakr’s services. We do so in order to fulfill our agreements with users, such as our Terms of Use, or based on users’ prior consent, adequacy decisions for the relevant countries, or other transfer mechanisms as may be available under applicable law. For Questions, comments, and complaints about our data practices please send a message or complaints to info@medtrakr.com

Communications

By creating an account, you consent to receive commercial emails from us. This includes newsletters and offers. Users from certain countries may have the ability to opt out or opt in at the time of account creation. All users may decline to receive commercial messages in their account settings. Please note that any opt-out request may take several days to process, and you will continue to receive transactional emails from us (e.g., emails confirming transactions and/or providing information about your account).

GDPR Statement for (EEA Users)

This applies only to natural persons residing in the European economic area (for the purpose of this section only, "you" or "“your" shall be limited accordingly). It is MedTrakr s policy to comply with the EU'S general data protection regulation (GDPR). In accordance with the GDPR, we may transfer your personal information from your home country to the United Kingdom (or other countries) based upon the following legal frameworks:

• Legitimate business interests: we could not provide our services or comply with our obligations to you without transferring your personal information to the United Kingdom
• Consent: we may transfer your personal information when we receive your express, revocable consent.
• Our use of standard contractual clauses (also known as "model clauses") where appropriate.
• You have the right to: opt out of non-essential cookies (see our cookie policy); access, correct, delete, restrict, or object to our use of your personal information; be forgotten; port your data; and withdraw consents.

We enable exercise of these rights primarily through our services (which we reserve the right to modify). We also fulfil our obligations in response to direct requests. We will endeavor to process requests within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person's rights. We reserve the right to request appropriate identification. We will process requests free of charge unless they would impose an unreasonable cost on us.

If you have a request, complaint or inquiry, please contact our data protection officer at the address listed below. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.

Security of Personal Information

The Site uses its best endeavors to store all Personal Information on servers with restricted access, and all electronic storage and transmission of Personal Information are secured with appropriate security technologies. Not to withstand the foregoing, the app cannot guarantee that such precautions would render the Site and its servers immune to security breaches.

Data retention and deletion

MedTrakr retains user data for as long as necessary for the purposes described above. Users may request deletion of their accounts at any time. MedTrakr may retain user data after a deletion request due to legal or regulatory requirements or for the reasons stated in this policy.

This means that we retain different categories of data for different periods of time depending on the category of user to whom the data relates, the type of data, and the purposes for which we collected the data

26.Precise Location Information and How to Opt Out

When you use one of our location-enabled services (for example, when you access Services from a mobile device), we may collect and process information about your mobile device's GPS location (including the latitude, longitude or altitude of your mobile device) and the time the location information is recorded to customize the Services with location-based information and features (for example, to inform you about your delivery in your area or applicable promotions). Some of these services require your personal data for the feature to work and we may associate location data with your device ID and other information we hold about you. We keep this data for no longer than is reasonably necessary for providing services to you. If you wish to use the feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer's instructions for further details.

27.Changes to our Privacy Policy

MedTrakr continually strives to implement new technologies and processes to better protect you, your privacy and your use of the MedTrakr service. As a result, changes to this privacy policy may be made by MedTrakr from time to time. In no event will these changes result in the degradation of any of the security measures designed to protect you from unauthorized disclosure, as such measures are described in this privacy policy.

28.Terms and Conditions

To learn more about our terms and conditions, please visit our Terms and Conditions page establishing the use, disclaimers, and limitations of liability governing the use of our website and web application.

29.Jurisdiction

This privacy policy, and terms of service, cookies, and other policies of MedTrakr Platform or services is governed by the English Laws.

30.Contact us

If you have any questions about this privacy policy, please contact us at info@MedTrakr.com