SmartSource Privacy Statement

This SmartSource Privacy Statement describes the information that AmerisourceBergen may collect about you during your visits to the Web Site (as defined in the “Terms of Use”); how we use and protect this information; who we share it with and for what purposes; and the choices you can make about how we use this information. Unless otherwise set forth in this Privacy Statement, capitalized terms shall have the same meaning as defined in the Terms of Use (this should be read in conjunction with this Privacy Statement). We may also update this Privacy Statement from time to time in accordance with new and changing regulatory requirements.   

By using the Web Site you consent to the processing of your information in the way described in this Privacy Statement.

Collection of Your Information
The amount and type of information we collect depends on how you use the Web Site. AmerisourceBergen may collect information about you from a variety of sources, including (a) information you provide directly; (b) information we collect about you when you visit our Web Site, use our services, or view our online advertisements; and (c) information we receive from other sources.

(a)    Information We Collect Directly From You.  We may collect information directly from you when you visit our Web Site, choose to use services or participate in programs or otherwise provide information directly to us. 

Information we collect directly from you may include User ID and Password; name, email address, postal address, telephone number; payment and credit-related details and information; other information about you such as date of birth, gender and other demographic information; product and service preferences and/or behaviors; and future communication preferences.

(b)   Information We Collect About You.  We may automatically collect information about you when you visit our Web Site, use our services, or view online advertisements.  We may log data or use tracking technologies such as cookies and web beacons to collect this information about you.  For more information about our use of tracking technologies, see our SmartSource Cookie Statement below.
           We may collect the following information about you:
·         Technical information, including your IP address, browser type and version, browser plug-in types and versions, operating system and platform, and device-specific information, such as time zone setting and mobile network information (including location information); and
·         Information about your visit, including, web pages you view, links you click, web sites you visited before coming to our Web Site, page response times, download errors, and page interaction information (such as lengths of visits to certain pages, scrolling, clicks and mouse-overs).

(c)    Information We Receive From Other Sources.  We work closely with third parties (which may include, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them. Please be advised that any information provided to us by a third party may also be subject to that third party’s privacy policy.

How We Use This Information
AmerisourceBergen may use the information we collect to provide you the services and products you request and to tell you about other services and products that may be available to you.  We also use the information to manage and maintain our Web Site.  Specifically, we may use this information as follows:

Information We Collect Directly From You. 

We may collect this information for uses that include, but are not limited to:
·         fulfilling our obligations arising from any contracts entered between you and us and providing you with the information, product and service you request;
·         providing you with other services that we have offered to you;
·         creating and managing your account;
·         developing and providing advertising tailored to your interests;
·         sending you service-related communications;
·         ensuring that content from the Web Site is presented in the most effective way for you and your computer.

Information We Collect About You.

We may collect this information for uses that include, but are not limited to:
·         administering and improving our Web Site, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
·         analyzing the use of our products and services;
·         measuring the effectiveness of the advertising we serve to you and others; and
·         making suggestions and recommendations to you and other users of our Web Site about goods that may interest you or them.

Information We Receive From Other Sources. 

We may combine the information we receive from other sources (such as our customers, suppliers, affiliates, public websites, public agencies, market research companies, contractors and consultants) with the information we collect directly from you and information we collect about you. We may use this information and the combined information for the purposes set forth in this Privacy Statement.

Sharing Your Information
Sharing Information With Third Parties.

Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.
When you provide personal information to AmerisourceBergen we may make it accessible to certain third party service providers to perform a variety of services on our behalf.  These service providers may include business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; advertisers and advertising networks for selecting and serving relevant adverts to you and others; and analytics and search engine providers for assisting us in the administration and improvement of the Web Site.  Please note that we provide our service providers with only the personal information necessary for them to perform services and only for use for such purposes. 

There may also be instances where AmerisourceBergen may share your personal information with third-parties who have not been retained by us (directly or indirectly), for example, if we are required to do so because of applicable law, a court order or governmental regulation; if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding here or abroad; in order to enforce or apply our Terms of Use or other agreements; and to protect the rights, property or safety of AmerisourceBergen or our customers.

Personal Information collected from you may also be transferred to a third party in the event that the business of this Web Site or a part of it is sold, assigned or transferred, or as part of the process of considering such a transaction, in which case we would use reasonable endeavors to ensure the actual or proposed buyer, assignee or transferee would treat your information in accordance with this Privacy Statement.
Sharing With AmerisourceBergen Affiliates.

AmerisourceBergen may share information we collect with AmerisourceBergen subsidiaries and affiliates.

Cookies, Web Beacons and other Technologies
We use cookies to give you the best possible experience on our Web Site.

By continuing to browse this site, you give consent for cookies to be used. For more details, including how you can amend your preferences, please review the following SmartSource Cookie Statement:

This section provides you with additional information on our use of cookies, web beacons and other technologies.

Cookies. A cookie is a small file placed on your computer when you visit a site that can be understood by the site that issued the cookie. We use cookies to monitor how our Web Site is used and to help personalize your online experience.  You can accept or decline cookies. Most browsers automatically accept cookies. To learn more about cookies, go to the cookie settings available in your specific web browser.

Web Beacons. Web beacons are small bits of code that communicate with third parties and are embedded in web pages, our ads or in emails. We may use web beacons to deliver or communicate with cookies, to count users who have visited a web page, to understand usage patterns or other third party functionality.  We also may include web beacons in e-mails to learn if messages have been opened, acted on, or forwarded.  You can disable the ability of Web beacons to store cookie information by declining cookies.
Other Technologies.  From time to time, we may use other technologies to provide better service to you.

Declining Cookies.  Although you are not required to accept cookies or provide AmerisourceBergen information when you visit its Web Sites, if you set your browser to reject cookies (or decide not to provide AmerisourceBergen certain information) you might not be able to use all of the features and functionality of this Web Site.

Use of Google Analytics
To better serve you and other potential customers, AmerisourceBergen has implemented Google Analytics Advertising features such as, but not limited to, Google Analytics Demographics and Interest Reporting.

Using the Google Ad Settings, you can opt-out of Google Analytics Advertising.
AmerisourceBergen will not facilitate the merging of Personally Identifiable Information with non-personally identifiable information collected through any Google Analytics Advertising features unless we provide you notice of, and obtain your prior affirmative (i.e., opt-in) consent to, that merger.
We and third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to our Web Site.
We and third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to your visits to our Web Site.

We may use data from Google’s Interest-based advertising or third-party audience data (such as age, gender and interests) with Google Analytics primarily to improve our marketing campaigns and Web Site content.

To learn more about Google Analytics Advertising, please click here: https://www.google.com/analytics/analytics/#?modal_active=none.  

Health Insurance Portability and Accountability Act (“HIPAA”)
Under HIPAA, each “covered entity” (health care provider, health plan or health care clearinghouse) is required to make available to you a Notice of Privacy Practices, depending on your interaction with the covered entity.  To the extent AmerisourceBergen is considered a covered entity based on your interaction with it, AmerisourceBergen will make available a Notice of Privacy Practices.  Such notice is separate from and not related to this Privacy Notice.

Security of Your Information
We use appropriate technical, administrative and physical safeguards to protect data that pertains to you from loss, misuse or alteration. Of course, no organization can guarantee the absolute security of personal information; any transmission is at your own risk. You should keep in mind that Internet transmissions, particularly email transmissions, are never 100% secure or error-free. Accordingly, we also caution you to guard your own computer and password against unauthorized access by others.

Links to Other Sites
This Privacy Statement applies only to this Web Site and not to third party websites. We may provide links to other websites.  We strive to link to third-party websites that meet a high set of standards. However, due to the nature of the World Wide Web, we cannot guarantee the privacy standards of websites to which we link or be responsible for the contents of sites other than this one. This Privacy Statement is not intended nor should it be construed to be applicable to any linked, non-AmerisourceBergen site.

International Transmission 
Users of the AmerisourceBergen Web Site acknowledge that the Internet is a global environment and using the Internet to collect and process data can involve the transmission of data on an international basis.  As described above, we may share your information with third parties and AmerisourceBergen subsidiaries and affiliates.  These companies may be located in, or use technology equipment, products and services located in, countries different to that in which your information is located or stored.  Where this is the case, we will take reasonable steps to ensure that your information receives the necessary level of protection and comply with applicable law.

By accessing and using our Web Site and communicating electronically with us, you acknowledge and accept our processing of data in this way. 

Protection of Children
AmerisourceBergen will not knowingly collect, use or disclose personally identifiable information from a minor under the age of 13, without obtaining prior consent from a person with parental responsibility (parent or guardian). AmerisourceBergen abides by laws protecting the privacy of children. Should a child whom we know to be under 13 provide personally identifiable information to us, we will use that information only to respond directly to that child to inform him or her that we must have parental consent before receiving information about him or her and then delete it.

Updating and Accessing Your Information
To the extent applicable to your use of the Web Site, we encourage you to update the information that you provide to us, such as providing us with a new mailing or email address. This will help us continue to provide information to you that best meets your needs.

In addition, AmerisourceBergen complies with laws and regulations applicable to the right to amend your data in our files. These rights are limited in some ways. In addition, in order to protect your data from unauthorized access or alteration by third parties, all requests to update or access your information will be subject to verification of the identity of the requesting individual.

Contact Us
If you have any concerns or questions or concerns about this Privacy Statement and the privacy practices set forth herein, including your dealings with this Web Site, please contact AmerisourceBergen directly at Privacy@amerisourcebergen.com.

Updated AmerisourceBergen Privacy Statement
This Privacy Statement becomes effective on June 1, 2019. AmerisourceBergen may update this Privacy Statement from time to time. We encourage you to review our Privacy Statement periodically.