Last Updated: September 1, 2023
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect, and have collected in the past twelve months, information that personally identifies, relates to, describes, or is capable of being associated with a person (“Personal Information”), including:
- identifiers (e.g., name, IP address, mailing address, email address, phone number);
- commercial information (i.e. account numbers, purchase history, payment activity)
- internet connection, the equipment you use to access our Website and usage details;
- characteristics of protected classifications under California and federal law (i.e. race, color, sex, age (40 and older), religion, national origin, citizenship status, genetic information, sexual orientation, gender identity or gender expression, ancestry, AIDS/HIV, disability, marital status, familial status)
- professional or employment-related information (i.e. employer and/or job title)
- inferences drawn from the above categories
- personal information as described in Cal. Civ. Code § 1798.80(e) to the extent collected under another category of Personal Information above.
Some of the Personal Information listed above may be considered sensitive under relevant privacy laws. This includes your customer account login credentials. We refer to this type of Personal Information as “Sensitive Personal Information” in this Policy. Each type of Sensitive Personal Information may overlap with a category of Personal Information listed above.
The types of Personal Information we collect about you may vary based on how you use the Site and/or Services and your relationship with us.
We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business. If such Business Information relates to a business contact person, we will treat it as Personal Information.
How we collect this information:
- Directly from you when you provide it to us.
- Third party data sources
- Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and/or other tracking technologies.
- We employ software technology that enables us to track certain aspects of a user’s visit to the Website. This technology helps us better manage content on the Website by informing us what content is effective, how consumers engage with the Website, and how consumers arrive at and/or depart from the Website. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user.
- Targeted and Cross-Context Behavioral Advertising
- Social Media Widgets
INFORMATION YOU PROVIDE TO US
The information we collect may include:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, making a purchase on our Website, subscribing to our emails or text messages, posting material or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
- Records and copies of your correspondence (including e-mail addresses, phone numbers, physical address, and other forms of identifiable information), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
- Your search queries on the Website.
- Information provided to us through social networks or third-party platforms when you, for example, engage with our social media content, or communicate with us via social media (such as your name, e-mail, profile picture, likes, location, friend list, photos or other information described by the applicable social network or platform).
USAGE DETAILS, IP ADDRESSES AND COOKIES
As you navigate through and interact with our Website, our advertising or applications on third-party websites and services, or otherwise engage with us through a computer or mobile device, we may automatically collect certain information about how you access and use the Website, information about the equipment you use to access the Website, and browsing actions and patterns, including:
- Information about how you use the Website, such as the pages you visit, the links you click, the ads you view and click on, purchase information and your checkout process, your location when you access or interact with our Website, and other similar actions;
- Analytics information to help us measure traffic and usage trends for the Website and to understand more about the demographics and behaviors of our users, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website;
- Information about the computer, tablet, smartphone or other device you use, including your IP address, operating system and browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, and other such information; and
- Information about how you access the Website, such as the site from which you came and the site to which you are going when you leave our Sites, how frequently you access the Website, when and whether you open emails or click the links contained in emails, whether you access the Website from multiple devices and other actions you take on the Website.
The information we collect automatically is statistical data and does not alone identify any individual. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
- The technologies we use for this automatic data collection may include a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”):
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. We may place tags on our webpages called “web beacons.” These are computer instructions that link web pages to particular web servers and their cookies.
THIRD PARTY WEB ANALYTICS SERVICES
You may deactivate the ability of Google Analytics to analyze your browsing activities on this Website. To disable Google Analytics, please download the browser add-on provided by Google at https://tools.google.com/dlpage/gaoptout?hl=en. To learn more about privacy and Google Analytics please consult the Google Analytics overview provided by Google at: https://www.google.com/intl/en/analytics/privacyoverview.html
We may also use third-party platforms and technology, including platforms operated by social networks, such as Google and Facebook to show you interest-based ads. These companies have specific Interest-Based Ads programs that match people that have shown interest in Total Diabetes Supply through our websites, stores or other services with users on their platforms and properties. If we participate in these programs, we convert your personal information (which may include name, email address or telephone number) or other information into a unique value which can be matched by those third parties with a user on their platform or with other data they may have collected from you. This matching allows us to deliver interest-based ads to users of these platforms. To opt-out of these ads, you must change your advertising preferences for those third-party platforms. You can manage your preferences for these advertising programs by clicking on the following relevant links: for Facebook click here, for Google click here. These platforms may have their own privacy notices or policies, which we strongly suggest you review.
- To our subsidiaries and affiliates.
- To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Total Diabetes Supply's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Total Diabetes Supply is among the assets transferred.
- To fulfill the purpose for which you provide it. For example, if you give us an e-mail address to use the "e-mail a friend" feature of our Website, we will transmit the contents of that e-mail and your e-mail address to the recipients.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
- We may also disclose your personal information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Total Diabetes Supply, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
USE OF INFORMATION
We collect and use Personal Information for internal purposes, such as to:
- Provide you with our Website and services;
- Process or complete transactions you requested;
- Improve the Website and services, including customization and personalization;
- Notify you of products and services via mail, email, telephone, and/or text messaging;
- Communicate with you about the Website, the services, and other matters via mail, email, telephone, and/or text messaging; and
- Compile information and analyses to enhance the customer experience and improve our business; and
- Perform day-to-day business operations such as accounting, seeking legal advice, pursuing or defending legal claims, maintaining information security and anti-fraud programs, and facilitating business transactions with our business partners and clients.
- We may use Sensitive Personal Information for the following purposes:
Customer account login credentials – To facilitate the transactions you requested and maintain our customer relationship with you.
From time to time, we may de-identify Personal Information so that it can no longer be reasonably linked, directly or indirectly, with an identifiable person. We may use and disclose de-identified information for any purpose since it is no longer Personal Information. We will not re-identify de-identified information.
We may establish a relationship with other businesses to provide services to us (“Service Providers”), including:
- Online hosting and maintenance;
- Marketing and promotion design and management;
- Communication facilitation such as printing and mailing or telecommunication services;
- Payment processing;
- Management of access to services;
- Data storage and management;
- Data analytics; and
- Identity and contact information validation.
We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us. We disclose each of the categories of Personal Information to one or more Service Providers.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us.
- Promotional Offers from the Company. If you do not wish to have your e-mail address, cell phone number or other contact information used by the Company to promote our own or our third-party partner’s products or services, you can opt-out by unchecking the relevant box located on the form on which we collect your data (the order form/registration form) or at any other time by sending us an e-mail stating your request to firstname.lastname@example.org. If we have sent you a promotional e-mail, you can tell us not to send you promotional e-mail by clicking on the unsubscribe link within the emails you receive from us. If you no longer wish to receive text messages, you can text STOP to the five digit short code for the text messaging program from which you no longer wish to receive messages (i.e., the five digit number from which the text messages are being sent).
We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. To learn more about advertising networks and to opt out of interest-based advertising, visit the Digital Advertising Alliance at www.aboutads.info/choices or the Network Advertising Initiative at www.networkadvertising.org/choices.
REVIEWING, UPDATING AND MODIFYING PERSONAL INFORMATION
Subject to applicable law, you may have the right to request access to and receive details about the personal information we maintain about you, update and correct inaccuracies in your personal information, and have the information blocked or deleted, as appropriate. The right to access personal information may be limited in some circumstances by local law requirements. We may take reasonable steps to verify your identity before granting access or making corrections. You may request to review, change or delete your personal information by sending an email to email@example.com.
CALIFORNIA DO NOT TRACK DISCLOSURES
Notice to Vermont Residents
In response to Vermont regulations, we automatically treat accounts with Vermont billing addresses as if you requested that we not share your information with nonaffiliated third parties, and that we limit the information we share with our affiliates. If we disclose information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transaction and experiences with you.
Notice to California Connecticut, Colorado, Utah and Virginia Residents
You have additional rights to access and control your Personal Information as described more fully below. We will retain a record of your request for at least two years and in compliance with applicable laws.
You have the right to request twice per 12-month period that we provide you (i) the categories and, if requested, specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; (iv) the categories of Third Parties with whom we shared your Personal Information; and (v) the business or commercial purpose for which we sold or shared your Personal Information.
You may have the right to request that we delete certain types of Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law. Please note that if you have a password-protected online account with us, we will fulfill your request via such account; otherwise, we will give you the option to receive your fulfillment by mail or electronic delivery.
You have the right to request that we correct any Personal Information that we have on file about you that you believe to be erroneous. When you make your request, please be sure to provide us the specific information that you believe is inaccurate and the correct information. You should also provide us with any documentation you believe supports your proposed correction, and we will take that documentation into consideration. We will only correct the information if we determine, based on the totality of the circumstances, that your correction is more likely than not accurate. We may also choose to delete the allegedly inaccurate information instead of correcting it. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law. Please note that if you have a password-protected online account with us, we will fulfill your request via such account; otherwise, we will give you the option to receive your fulfillment by mail or electronic delivery.
If you are a California resident, you have the right to request that we limit the use of your Sensitive Personal Information as defined under California law to only exempt purposes such as to provide the goods and services reasonably expected by the average consumer who requests such goods and services, to prevent fraud, and to verify or maintain the quality or safety of goods or services we provide.
If we deny your privacy request, in full or in part, you may appeal our decision. If we deny your appeal, you may also contact your state Attorney General to lodge a complaint and we will provide you with an online mechanism to do so. We will process requests to appeal within the timeframes established under applicable law, but typically within 45 days. Please note that if you have a password-protected online account with us, we will fulfill your request via such account; otherwise, we will give you the option to receive your fulfillment by mail or electronic delivery.
Notice to Users Outside of the United States
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
HOW LONG WE RETAIN YOUR DATA
We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations.
Children Under 18
Our Website is not intended to be used by children under 18 years old. You represent and warrant that you are at least 18 years of age. If you are under age 18, you may not use the Website or services. We do not knowingly collect personal information from, or target our Website or services to children under the age 18. We understand that there may be exceptions to this rule including, but not limited to children who are emancipated. If we discover that the Website is being used inappropriately, we will take steps, if possible, to disable access so that the individual may no longer access our Website.
Total Diabetes Supply supports Shoppers’ rights in the following ways:
- Access, Rectification, and Deletion. If you are located in the EEA, you have certain rights under European law with respect to your personal data, including the right to request access to, correct, amend, delete, or limit the use of your personal data. You may request to review, change or delete your personal information by sending an email to firstname.lastname@example.org
- Breaches. Total Diabetes Supply shall notify its users in the event of any breach or unauthorized access to Shoppers’ PII of the following information: the existence and nature of such breach, our Data Protection Officer, possible or likely consequences, and measures taken to address or, where possible, mitigate the breach.
If you have any questions about your personal information or this policy, please contact us by email at email@example.com, or by using the contact details below:
Total Diabetes Supply
3200 West Prospect Road Ste. 100
Fort Lauderdale, FL 33309