Last Updated: February 11, 2025
This Privacy Policy (the “Privacy Policy”) applies to the EmpoweRx Marketplace (“Website” or “Technology Platform” or “EmpoweRx Marketplace” or “Websites” or “Site”) and its associate website, other company software, services, websites, or content (collectively the “Services”), owned and operated by EmpoweRx, Inc. (“EmpoweRx,” “we,” “us,” or “our”). We have created this Privacy Policy to tell you what information the Site collects, how we use that information, and who we will share that information with, if at all. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. Capitalized terms not defined in this Privacy Policy will have the meaning stated in our Terms of Use. By visiting and/or using our Site, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use. We encourage you to read the Privacy Policy, and to use the information it contains to help you make informed decisions.
We may update and make changes to this policy, so we encourage you to review it periodically.
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | EmpoweRx, Inc. |
| Personal information | Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular individual or household. |
| Sensitive personal information | Personal information revealing an individual’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning an individual’s health, sex life, or sexual orientation, contents of an individual’s mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, and citizenship or immigration status. |
In the preceding 12 months, we have collected the following categories and specific types of personal information from and about you:
| Categories of Personal Information | Specific Types of Personal Information Collected |
| Identifiers (e.g., full name, unique personal identifier, online identifier, Internet Protocol (“IP”) address, email address, account name, or similar identifiers) | Name, date of birth, IP address, email address, profile data, username and password, email address. |
| Information that identifies, relates to, describes, or is capable of being associated with a particular individual, including, but not limited to, their name, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | Name, email address, address, telephone number, social security number, passport number, driver’s license or state identification card number, professional liability insurance policy number, vaccine records, panel drug test results, criminal background check results, FACIS background check results, bank account number, payment card information, user-generated content, communication information (e.g. content sent via the Site’s communication services). |
| Characteristics of protected classifications under state or federal law | Date of birth, gender, age, nationality, racial or ethnic origin, religion, marital status, citizenship status, military or veteran status, and disability information. |
| Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding an individual’s interaction with an Internet Website, or application.) | Website interaction history, website cookie information, browsing time. |
| Commercial information (e.g., records of services purchased) | Subscription purchase history. |
| Geolocation data | Approximate location |
| Audio/Visual Data. | Profile photographs. |
| Professional or employment-related information | Work history, previous places of employment, previous positions, professional references, earnings, education history, degrees, transcripts, certifications, and professional licenses. |
| Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Profile information reflecting user preferences, traits, and behaviors. |
| Sensitive Personal Information | Social security number, passport number, driver’s license or state identification card number, vaccine records, panel drug test results, criminal background check results, FACIS background check results, bank account number, payment card information, communication information (e.g. content sent via the Site’s communication services). |
We collect most of this personal information directly from you—via the Site or by email, telephone, or text. However, we may also collect information from the following categories of sources:
We collect, and share your personal information for the following business purposes:
In the preceding 12 months, we have shared users’ personal information with:
We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We do not sell or share, as defined in the California Consumer Privacy Act of 2018 (CCPA) and as amended by the California Privacy Rights Act of 2020 (CPRA), your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale or sharing.
In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:
We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
The Site and our Services are not intended for use by children under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently received personal information from a child under 18, we will delete such information from our records. If you are a parent or guardian and believe that your child under 18 has provided us with personal information, please contact us at admin@empowerxinc.com so that we can take appropriate action.
We prioritize the protection of your personal information and employ a range of security measures to safeguard it from accidental, unlawful, or unauthorized access, use, alteration, loss, destruction, or disclosure. These measures include technical, administrative, and physical safeguards designed to protect your data.
We may use your personal information to send you marketing emails about our services and promotions. If you prefer not to receive these communications, you can opt-out at any time by following the unsubscribe instructions provided in the email or by contacting us directly at marketing@empowerxinc.com. Your choice to opt-out of marketing emails will not affect other communications necessary for the provision of the Services.
The EmpoweRx Marketplace uses Stripe, Inc. (“Stripe”), a third-party payment processor, to handle payments on our behalf. When a Remittance payment is made, your personal information will be processed by Stripe in accordance with their privacy policy. For more information on how Stripe handles your data, please review Stripe’s Privacy Policy here: https://stripe.com/privacy.
If you are a resident of California, you have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the 8 California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:
| Disclosure of Personal Information We Collect About You | You have the right to know, and request disclosure of: • The categories of personal information we have collected about you, including sensitive personal information; • The categories of sources from which the personal information is collected; • Our business or commercial purpose for collecting, selling, or sharing personal information; • The categories of third parties to whom we disclose personal information, if any; and • The specific pieces of personal information we have collected about you. Please note that we are not required to: • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or • Provide the personal information to you more than twice in a 12-month period. |
| Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose | In connection with any personal information, we may share, or disclose to a third party for a business purpose, you have the right to know: • The categories of personal information about you that we shared and the categories of third parties to whom the personal information was shared; and • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose. You have the right to opt-out of the sale of your personal information or sharing of your personal information for targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information. Please understand that we do not sell any user information, including personal information. To opt-out of the sale or sharing of your personal information, please contact us at admin@empowerxinc.com. |
| Right to Limit Use of Sensitive Personal Information | You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to: • Perform the Services reasonably expected by an average consumer who requests the Services; • To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the individual’s personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a individual’s current interaction with the business, if the individual’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the individual’s experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by the business, and to improve, upgrade, or enhance the service owned, or controlled by the business; and • As authorized by further regulations. You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. To limit the use of your sensitive personal information, please contact us at admin@empowerxinc.com. |
| Right to Deletion | Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: • Delete your personal information from our records; and • Direct any service providers or contractors to delete your personal information from their records. • Direct third parties to whom the business has sold or shared your personal information unless this proves impossible or involves disproportionate effort. Please note that we may not delete your personal information if it is reasonably necessary to: • Complete the transaction for which the personal information was collected, provide the Services requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; • Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes; • Debug to identify and repair errors that impair existing intended functionality; • Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law; • Comply with the California Electronic Communications Privacy Act; • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; • Comply with an existing legal obligation; or • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. |
| Right of Correction | If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information. |
| Protection Against Retaliation | You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: • Deny Services to you; • Charge different prices or rates for Services, including through the use of discounts or other benefits or imposing penalties; • Provide a different level or quality of gServices to you; or • Suggest that you will receive a different price or rate for Services or a different level or quality of Services. Please note that we may charge a different price or rate or provide a different level or quality Services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information. |
If you are a resident of Nevada, you have the right to request that we do not sell your “personal information” which is subject to the Nevada Privacy of Information Collected on Internet From Consumers Act (NPICICA). To exercise this right, please contact us at admin@empowerxinc.com. In order for us to verify your identity and process your request, you must provide us with your name, email address, and telephone number.
Please understand that we do not sell any user information, including personal information
Depending on your state of residence, you may have certain privacy rights regarding your personal information. These rights can include:
Right to Confirm and Access: You may have the right to confirm whether we are processing personal information about you and to request access to the personal information we hold about you.
Right to Correction: You may have the right to request that we correct any inaccuracies in your personal information.
Right to Deletion: You may have the right to request that we delete your personal information, subject to certain exceptions.
Right to Data Portability: You may have the right to request a copy of your personal information in a portable and readily usable format.
Right to Opt-Out: You may have the right to opt out of the sale of your personal information.
Right to Restrict Processing: You may have the right to restrict or object (“opt-out”) to certain types of processing of your personal information.
To exercise these rights, please contact us using the information provided in Section 16 of this policy. We may need to verify your identity before processing your request to ensure the security of your personal information. The specific rights available to you may vary based on the laws of your state and whether certain information is exempt from the rights described above under applicable law.
If you would like to exercise any of your rights as described in this Privacy Policy, you may email us at admin@empowerxinc.com.
Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly by email, you will need to provide us with:
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.