Internet Privacy Policy

http://www.pti-nps.com (“Site”) is owned and operated by Pharmaceutical Technologies, Inc.® d/b/a/ P.T.I.® National Pharmaceutical Services (NPS) and The Pharmacy Smartcard SMARTCARD(collectively “PTI”). PTI is firmly committed to protecting the confidentiality of your personal and medical information. When you enroll in any of our services directly via this Site or through your employer, you are providing information on a voluntary basis. By visiting and using this Site, you assent to this Privacy Policy. If you have any questions or concerns about this Internet Privacy Policy, or about the way your information is collected and/or used, please contact us via email at help@pti-nps.com

According to the DEFINITIONS attached, we have developed the following practices and policies to safeguard your information.

Your Non-Personal Information

When you visit a Site page, we may collect non-personal information from you, such as the Internet browser or computer operating system you are using. We use this information to provide you with better service and to improve this Site. We will not sell or disclose non-personal information to other companies or organizations.

Your Personal Information

When you register for a service through PTI or make service elections such as signing up for a SMARTCARD, you may voluntarily provide us with personal information.

PTI will not sell or disclose your personal information or protected health information (hereinafter, PHI) to other companies and/or organizations except as stated in this Internet Privacy Policy or as otherwise disclosed at the time of collection.

PTI will only use your personal and health-related personal information for the following purposes:

PTI also reserves the right to use your personal information or PHI to generate aggregate data for the following purposes:

Under certain circumstances, PTI may be legally compelled to release your personal information or PHI in response to a court order, subpoena, search warrant, law or regulation. Under these circumstances, we may notify you unless doing so would violate the law and/or court order. Pursuant to the federal Health Insurance Portability and Accountability Act (HIPAA), PTI is required to safeguard your individually identifiable health information as PHI.

Information on Our Site Security

The information for the account(s) you have with PTI is kept secure and confidential through multiple security features and procedures:

Family Member Information

This Site may include features through which Members in a program administered by PTI can request their prescription history for covered household members.

To request prescription history information for adult dependents, the member must certify at the time of registration that permission has been obtained from the affected dependents. The member also must agree to use the dependents’ prescription history solely for the purposes of prescription benefit management. Prescription history cannot be used for any other purposes without the written consent of the adult dependents.

Usage by Children

This Site is neither intended nor designed to attract users who are minors. Where appropriate, we specifically instruct minor children not to submit such information without the consent of a parent or guardian.

To request the removal of personal information submitted by a minor child, please send an e-mail to help@pti-nps.com

Cookies

When you view this Site, we may store information on your computer. This information will be in the form of a cookie or similar file and will be used to determine ways to improve this Site, advertisements, products or services. With most Internet browsers, you can erase cookies from your hard drive, block all cookies, or receive a warning before a cookie is stored.

E-mail Privacy

You can choose to receive e-mail from PTI on selected health topics and/or promotions. These e-mail messages include instructions for discontinuing their receipt. You can also use this Site to send an e-mail inquiry to PTI which may result in a reply being sent to an e-mail address that you provide.

Responses sent from the PTI customer service team to your e-mail provider may not be secure or may be intercepted by third parties. By using the e-mail service, you accept the risk of transmitting information from PTI to your personal e-mail address in an unsecure environment.

If you are receiving e-mail correspondence at an employer’s e-mail address, please note that, under law, the employer may be permitted to review the contents of any e-mail messages received at this address. If you are concerned about the confidentiality of your e-mail messages, you may wish to use a home e-mail address.

Correct and/or Update Your Information

You can correct or update your personal health-related personal information at any time using the following options:

Or

Sale or Transfer of Information in the Event of Merger, Sale or Bankruptcy

PTI considers the information obtained through this Site to be important assets of PTI. As a result, in the event PTI is acquired, merges with another entity, becomes insolvent and/or declares bankruptcy, this Site and/or any information obtained through it may be transferred or sold to another entity in accordance with applicable law.

Links to Other Sites

This Site may include links to other websites that are not related to, or are not the property of, PTI. We are not responsible for the accuracy and security of these other websites and the Internet Privacy Policy applies only to this Site.

Changes to this On-Line Privacy Policy

PTI uses your personal and health-related personal information only as described in the Internet Privacy Policy when the information is collected from you directly or indirectly. However, we reserve the right to change this Internet Privacy Policy at any time. Changes to the Privacy Policy will be posted on this Site.

Therefore, we recommend that you visit this page periodically so that you will be apprised of any changes.

How to Send Us Your Comments

We welcome your comments. If you have general feedback regarding this Internet Privacy Policy, please send an e-mail to help@pti-nps.com

Specific questions regarding the enforcement of this policy should be directed to PTI Legal Department, c/o James D. Buser, PANSING HOGAN ERNST & BACHMAN LLP, 10250 Regency Circle, Suite 300, Omaha, Nebraska 68114.

DEFINITIONS

PTI means Pharmaceutical Technologies, Inc.®, National Pharmaceutical Services® (NPS), and IHMO Pharmacy and any other entity or group that is a division of or controlled by Pharmaceutical Technologies, Inc.®, a Nebraska corporation.

Non-Personal Information means information that cannot personally identify a user of this website or be used to contact the user. Examples include (1) type of Internet browser, (2) type of computer operating system and (3) the domain name of the website and/or Internet service provider from which a user linked to this website, and so on.

Personal Information means information that could be used to identify or contact a user of this website. Examples include your name, birthday, e-mail address, mailing address, policy information, social security number, telephone number, and so on.

Protected Health Information (PHI) means individually identifiable health information as defined under the Health Insurance Portability and Accountability Act (HIPAA) at 45 C.F.R. § 160.103.

Aggregate Data means summary level data, such as the number of SMARTCARD members of a specific gender, in a specific zip code, that have chosen a specific pharmacy. Aggregate data does not contain information that can be used to identify or contact a user of this website, such as the user’s name, address, telephone number or e-mail address. Aggregate Data may consist of de-identified data, as defined by HIPAA.

Cookie is a unique identifier that a website transfers to a user’s hard drive for record-keeping purposes. PTI’s cookies are used to personalize a user’s on-line experience and include only information that a user or the user’s employer has already provided to PTI. Our cookies are deleted from the user’s hard drive when he or she closes the browser session.

Server is the computer or computer program that houses and/or distributes data.

Firewall is a set of related programs that protects the resources of a private network from users from other networks.

Cardholder or Member is the policyholder of the prescription benefit administered by PTI or SMARTCARD policyholder. Dependents are covered by the cardholder’s benefit.

Adult Dependent is a dependent 18 or more years of age. Adult dependents have privacy rights through which they may choose not to share their prescription history information with other household members, including spouses, parents or guardians.

©2009 Pharmaceutical Technologies, Inc.

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