Last modified: December 7, 2018

Introduction

Two Labs Holdings, LLC and its subsidiaries and affiliates. (“Company” or “We” or “Two Labs“) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit twolabs.com,  mkogp.com, or Pennside.com (collectively, the “Websites”) and our mobile applications (collectively, the “Apps” and with the Websites, the “Services”), whether as a guest or a registered user and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On or through the Services.
• In email, text, and other electronic messages between you and the Services.
• Through Apps including without limitation any mobile or desktop applications you download from Services, which provide dedicated non-browser-based interaction between you and any Services.
• When you interact with our advertising and applications on third-party Services and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• us offline or through any other means; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Services

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using the Services, you acknowledge this privacy policy. This policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Services are not intended for children under 13 years of age. No one under age 13 may provide any information to or through the Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on or through the Services or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@twolabs.com.

Transfer of Information

The Services may be stored and processed in the United States. If you are located in the European Economic Area (“EEA”) or elsewhere outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Services or providing us with any information, you acknowledge this transfer and the processing of information in the United States.

Protected Health Information

Our Website and Apps are not intended for use with protected health information. We do not desire to receive, nor are you permitted to provide or otherwise make available through our Services any protected health information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Services, including information:

• by which you may be personally identified, such as name, postal address, e-mail address, and/or telephone number (“personal information“); and/or
• about your internet connection, the equipment you use to access our Services and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. 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:

• Information that you provide by filling in forms on our Websites or Apps. This includes information provided at the time of reporting a case through our eRx and Trade Apps, or requesting publications through our Services, or requesting further information about our services, including without limitation about the Services. We may also ask you for information when you report a problem with our Services.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes, including without limitation through our MTracker App.
• Your search queries on the Services.

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Services or transmitted to other users of the Services or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies.  As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Websites, including traffic data, logs, and other communication data and the resources that you access and use on the Services.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns. (If you are located in the EEA our lawful basis for such processing is legitimate interest.)
• Store information about your preferences, allowing us to customize our Websites according to your individual interests. (If you are located in the EEA our lawful basis for such processing is legitimate interest.)
• Speed up your searches. (If you are located in the EEA our lawful basis for such processing is legitimate interest.)
• Recognize you when you return to our Websites. (If you are located in the EEA our lawful basis for such processing is legitimate interest.)

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer.
• Web Beacons. Pages of our the Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email, and for other related Services statistics (for example, recording the popularity of certain Services content and verifying system and server integrity). (If you are located in the EEA our lawful basis for such processing is legitimate interest.)

How We Use Your Information

We use information that we collect about you or that you provide to us through the Services, including any personal information:

• To present our Services and its contents to you. (If you are located in the EEA our lawful basis for such processing is legitimate interest, unless we have a contract with you or your organization, and then the lawful basis is the performance of a contract.)
• To provide you with information, products, or services that you request from us. (If you are located in the EEA our lawful basis for such processing is legitimate interest, unless we disclose an alternative lawful basis at such time.)
• To fulfill any other purpose for which you provide it. (If you are located in the EEA our lawful basis for such processing is legitimate interest, unless we have a contract with you or your organization, and then the lawful basis is the performance of a contract, unless we disclose an alternative lawful basis at such time.)
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. (If you are located in the EEA our lawful basis for such processing is the performance of a contract.)
• To notify you about changes to our Services or any products or services we offer or provide though it. (If you are located in the EEA our lawful basis for such processing is legitimate interest, unless we have a contract with you or your organization, and then the lawful basis is the performance of a contract, unless we disclose an alternative lawful basis at such time.)
• To allow you to participate in interactive features on our Services, including the download of white paper resources. (If you are located in the EEA our lawful basis for such processing is legitimate interest, unless we have a contract with you or your organization, and then the lawful basis is the performance of a contract, unless we disclose an alternative lawful basis at such time.)
• In any other way we may describe when you provide the information. (If you are located in the EEA our lawful basis for such processing is legitimate interest, unless we have a contract with you or your organization, and then the lawful basis is the performance of a contract, unless we disclose an alternative lawful basis at such time.)
• For any other purpose with your consent. (If you are located in the EEA our lawful basis for such processing is Consent.)
• We may also use your information to contact you about our services that may be of interest to you. (If you are located in the EEA our lawful basis for such processing is Consent.)

In addition to the forgoing, we may use information that we collect about you or that you provide to us through our Apps, including any personal information:

• To establish user accounts; gather data to be used in submitting state license applications through our PharmaLicense Portal. (If you are located in the EEA our lawful basis for such processing is the performance of a contract.)
• To establish user accounts; gather survey responses within the M-Tracker App. (If you are located in the EEA our lawful basis for such processing is the performance of a contract.)
• To resolve issues/cases within the eRx/Trade Apps. (If you are located in the EEA our lawful basis for such processing is the performance of a contract.)

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates. (If you are located in the EEA our lawful basis for such processing is legitimate interest.)
• 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. (If you are located in the EEA our lawful basis for such processing is legitimate interest.)
• 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 Two Labs’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Two Labs about our Services users is among the assets transferred. (If you are located in the EEA our lawful basis for such processing is legitimate interest.)
• To fulfill the purpose for which you provide it. (If you are located in the EEA our lawful basis for such processing is legitimate interest, unless we have a contract with you or your organization, and then the lawful basis is the performance of a contract, unless we disclose an alternative lawful basis at such time.)
• For any other purpose disclosed by us when you provide the information. (If you are located in the EEA our lawful basis for such processing is legitimate interest, unless we have a contract with you or your organization, and then the lawful basis is the performance of a contract, unless we disclose an alternative lawful basis at such time.)
• With your consent. (If you are located in the EEA our lawful basis for such processing is Consent.)
• Through the use of HubSpot, LinkedIn, G+, and Google Analytics. (If you are located in the EEA our lawful basis for such processing is legitimate interest, unless we disclose an alternative lawful basis at such time.)

Additional information on how Google Analytics collects and processes data may be made available by Google at the following Services: www.google.com/policies/privacy/partners/.

Please note that you may opt-out of having or making your site activity available to Google Analytics by installing the Google Analytics opt-out browser add-on provided by Google. Additional information may be made available by Google at the following website: https://support.google.com/analytics/answer/181881?hl=en&ref_topic=2919631

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.
• To enforce or apply our Terms of Use other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Two Labs, our customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent; however, due to the varying practices of organizations that offer browsers and the lack of a standard in the marketplace, we generally do not respond to do not track (“DNT”) signals sent via browsers at this time. In general, our system will issue cookies when you direct your browser to our Websites.
• Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to info@twolabs.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

Accessing and Correcting Your Information

You may also send us an email at privacy@twolabs.com to request access to, correct or delete certain personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Services, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Services users. Proper access and use of information provided on the Services, including User Contributions, is governed by our Terms of Use.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@twolabs.com or write us at: Two Labs Data Privacy, 110 Riverbend Ave., Suite 100, Powell, OH 43065.

Your Rights under the General Data Protection Regulation

In the event you provide personal data on or through our Services while located in the EEA, you may have certain rights under the EU General Data Protection Regulation’s (Regulation (EU) 2016/679) (“GDPR”) and other laws. Depending on our legal basis for processing your personal data, you may have some or all of the following rights:

• The right to be informed. You have the right to be informed about the personal data we collect from you, and how we process it.
• The right of access. Subject to certain exceptions, you may have the right to request a copy of the Personal Data we are processing about you.  If you request multiple copies, we may charge an administration fee.
• The right to rectification. You have the right to require any of your personal data be corrected, if it is inaccurate or incomplete.
• The right to erasure (right to be forgotten). You have the right to request the removal or deletion of your personal data that we process about you, unless we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims, or if there is no compelling reason for us to continue processing it.
• The right to restrict processing. You have a right to request that we restrict our processing of your personal data where: (i) such data is inaccurate, (ii) our processing is unlawful, or (iii) we no longer need to process such data for a particular purpose and we are unable to delete the data due to a legal or other obligation.
• The right to data portability. You have the right to request that we transmit the personal data we hold of yours to another data controller, provided that you provided such personal data to us and that we are processing such personal data on the basis of your consent or in order to perform our obligations under contract with you, and the processing is carried out by automated means.
• The right to object. You have the right to object to us processing your personal data if the processing is based on our legitimate interest. We will comply with your request unless we have a compelling legitimate basis for the processing which overrides your interests and rights, or our processing relates to the establishment or exercise of the defense of a legal claim.
• The right to withdraw consent. If we are processing your personal data pursuant to the lawful basis of consent, you have the right to withdraw such consent at any time, without charge. This includes, without limitation, your ability to opt-out from marketing messages that you receive from our affiliates.
• Automated individual decision-making and profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• Right to file a complaint. If you are in the EU, and you believe we have not complied with the applicable data protection laws, you also have the right to file a complaint with the local data protection authority. A list of data protection authorities in the EU is made available by the Board at the following link: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

Data Security

The safety and security of your information depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. The information you share in public areas may be viewed by any user of the Services.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the applicable Website home page, and in the applicable App store and marketplace. If we make material changes to how we treat our users’ personal information, we will use commercially reasonable efforts to notify you by email to the primary email address you provided to us. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Services and this privacy policy to check for any changes.

Data Controller Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Two Labs Data Privacy, 110 Riverbend Ave., Suite 100, Powell, OH 43065

or via:

614-389-4004, Option 9

or via: privacy@twolabs.com