ZOIA Pharma Privacy Policy

Pentec Health, Inc., its subsidiaries, and affiliated entities (“Pentec,” “we” or “us”) respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Privacy Policy”). This Privacy Policy describes how Pentec collects, uses, and discloses personal information about individuals who use our websites at www.pentechealth.com, www.zoiapharma.com, www.zoiahealthcare.org, www.diamondnutritioncounseling.com, www.mypentec.com, www.care.mypentec.com and all corresponding webpages, software applications, or mobile applications that link to this Privacy Policy (collectively, the “Sites”). This Privacy Policy applies solely to the information that we collect through the Sites.  This Privacy Policy does not address personal information that you provide to us in other contexts (e.g., through a business relationship not handled through the Sites). Please note this Privacy Policy does not cover our use, collection, or disclosure of your Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act (“HIPAA”). For more information about these practices, see our HIPAA Notice of Privacy Practices [www.pentechealth.com/hipaa-compliance].

Acceptance of Privacy Policy

By using the Sites, you signify your acceptance of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Sites. 

Collection of Personal Information

Personal information generally means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with you (“Personal Information”). Personal information does not include information that is publicly available, de-identified, or aggregated. We may combine your Personal Information with data we obtain from our services, other users, or other parties. We reserve the right to convert, or permit others to convert, your Personal Information into de-identified or aggregated data as permitted by law. What Personal Information we collect may differ depending on how you interact with us.

The types of information we may collect could include:
•    Customer Information
•    Contact Information
•    Usage Information
•    Employment Information
•    Communication Information

How We Collect Personal Information:

We may collect your Personal Information directly from you, from other parties, or from you indirectly through cookies and other technologies, including through the following sources: 

  • Directly from You
  • From our affiliated companies
  • Through technologies in use on the Sites (such as through cookies, pixels, and other tracking technologies)
  • Created by us (e.g., if we create records pertaining to you, provide you with a login or user ID, or otherwise generate information linked to you)
  • Service providers that help us to run our business
  • Advertising networks, social networks, internet service providers, and data analytics providers

How We Use Your Personal Information?

If you choose to provide us with Personal Information by completing a form on the Sites or emailing us, we will use that Personal Information to (i) operate the Sites, (ii) respond to your question or request, (iii) communicate with you about our products or services via email or text, (iv) send information to you and respond to customer service related inquiries, (v) provide marketing materials and communications about our products or services and (vi) notify you of changes to this Privacy Policy. 
When you contact us through the “Contact Us” section of our Sites, you may be given the option of receiving recurring informational/promotional newsletters or other emails from Pentec.  In order for you to subscribe to these emails, we may ask for your contact information.  You can unsubscribe from Pentec emails at any time by simply following the directions included at the bottom of each email or as described in the "Updating Your Information" section below. If you have difficulties with our newsletters or emails that you cannot address as described above, please see the contact information in the “For Additional Information” section below and let us know about your issue.

How We Disclose Personal Information

Unless you expressly give us permission in writing to do so, Pentec will not sell, rent, license, or trade your Personal Information other than as specified in this Privacy Policy.
We disclose personal information to our affiliates, service providers, and contractors in the following circumstances: 
  • Performing services (including processing, maintaining, or collecting personal information) on our behalf related to the operation of our business and/or the Sites (e.g., providing communications, technical, analytical, web hosting, cloud hosting, or other services)
  • As your potential employer
  • Auditing related to ad impressions
  • Ensuring security and integrity of personal information
  • Debugging to identify and repair errors that impair existing intended functionality
  • Short-term, transient use, including, but not limited to, non-personalized advertising
  • Providing advertising or marketing services on our behalf (except for cross-context behavioral advertising)
  • Undertaking internal research for technological development and demonstration
  • Undertaking activities to verify or maintain the quality or safety of our Sites
  • To comply with applicable laws and regulations
  • For safety and security
  • Detecting, protecting against, or addressing malicious, deceptive, fraudulent, or illegal activity
In addition to the purposes described above, we may use and disclose any category of personal information we collect to respond to law enforcement requests, or as otherwise required or authorized by applicable law, court order,  or  governmental  regulations;  to  protect  our  rights  and  interests  and  those  of  others;  to  resolve  any disputes; to enforce our policies; and to evaluate or conduct a merger, sale, or other acquisition of some or all of our assets. 

Automatically Collected Information and Anonymous Information

We use cookies, web beacons, embedded scripts, software development kits and other similar tracking technologies (collectively, “Tracking Technologies”) that automatically collect personal information as you interact with the Sites. We use Tracking Technologies to personalize your experience with our Sites, support the functionality of our Sites, analyze trends relating to usage of the Sites, and for advertising purposes. Our Sites use first-party Tracking Technologies as well as Tracking Technologies supported by our service providers and third parties, such as advertising partners. The length of time a cookie will stay on your device depends on whether it is a “session” or “persistent” cookie. Session cookies generally stay on your device until you stop browsing. Persistent cookies stay on your device until they expire or are deleted. We use both session cookies and persistent cookies on our Sites. In general, our Sites use cookies and other tracking technologies as follows:
  • When necessary to operate our Sites (for example, for security purposes) 
  • To optimize the functionality of our Sites, including by personalizing content for you and remembering your preferences 
  • For purposes of ad targeting and marketing. These cookies collect information about your browsing behavior on our Sites to show you relevant advertising when you visit other websites or use social media
  • We use analytics services, including Google Analytics, to assist us with analyzing our website traffic. These services utilize cookies and other technologies that collect your Personal Information.  To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ websites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.For analytics purposes. For example, to help us understand how our Sites are used. More information on website analytics is provided below. If you do not want to have cookies placed on your device, you should set your browser to refuse cookies before accessing our Sites.  You can find more information about how to change your browser cookie settings atallaboutcookies.org, 

How Long Do We Retain Your Information:

We retain your Personal Information for as long as necessary to provide you services/potential services and in accordance with the Company’s data retention schedule. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, resolve disputes, or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you.
To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; applicable legal requirements, etc.

Security

The security of your data is very important to Pentec. Pentec and our service providers have implemented appropriate security measures preventing your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. However, you should know that no website operator, including Pentec, can fully eliminate security risks associated with Personal Information. While Pentec has endeavored to create a secure and reliable online environment for users, the confidentiality of any communication or material transmitted to/from our Sites or via e-mail cannot be guaranteed.

Children's Privacy Protection

Under Age 13.  Pentec understands the importance of protecting children's privacy in the interactive online world. The Sites are not designed for, or intentionally targeted at, children under 13 years of age. It is not our policy to intentionally collect or maintain information about anyone under the age of 13.  No one under the age of 13 should submit any Personal Information to Pentec or the Sites.
Under Age 18.  Minors under 18 years of age may have the Personal Information that they have provide to Pentec through the Sites deleted by sending an email to marketing@pentechealth.com requesting deletion.  Please note that, while we make reasonable efforts to comply with such requests, deletion of your Personal Information does not ensure complete and comprehensive removal of that data from all systems.

Notice to California Residents

This section applies to our collection and use of Personal Information if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations, and as amended by the California Privacy Rights Act (“CCPA”), where “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you.  Personal information does not include information that is publicly available, de-identified or aggregated.  This notice does not apply to Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act (“HIPAA”).
Pentec makes the following disclosures regarding the Personal Information it has collected within the 12-month period preceding the Effective Date of this Privacy Notice.  The specific Personal Information we collect about you may vary depending on the nature of your relationship with us and may not include all of the examples listed below

Types of Personal Information We May Collect

The specific Personal Information we collect about you may vary depending on the nature of your relationship with us and may not include all of the examples listed below.
Identifiers – such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, or other similar identifiers.
Other elements – such as name, signature, characteristics or description, address, telephone number, education, bank account number, credit card number.
Characteristics of protected classifications under California or federal law – such as race, religion, and age.
Commercial information – such as products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Education information – such as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
Internet or other electronic network activity – such as browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.
Biometric information – such as an individual’s physiological, biological, or behavioral characteristics used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity.
Geolocation data – such as location information while using one of our apps.
Audio, electronic, visual, thermal, olfactory, or similar information – such as identifiable information obtained about you from voicemail messages, while speaking with our service representatives, including on the telephone, and captured by video cameras.
Sensitive Information — Sensitive information means a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; the processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health; and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

Sources of Personal Information

We collect Personal Information from the categories of sources detailed in the How We Collect Personal Information section above. 

Use of Personal Information

Personal Information may be used for the business and commercial purposes detailed in the How We Use Your Personal Information section above.

Disclosure of Personal Information

The categories of third parties to whom we disclose Personal Information for a business or commercial purpose are listed below:  
  • Service Provider 
  • Business Partners
  • Third Parties for legal, security or safety purposes
  • Third Parties in connection with a corporate transaction
  • Other entities to which you have requested a disclosure 

Retention of Personal Information

Personal Information will be retained as detailed in the How Long Do We Retain Your Information section above.
Pentec does not sell or share (i.e., engage in cross-context behavioral or targeted advertising) Personal Information about you to third parties. Pentec does not use or disclose sensitive personal information for any purposes other than those permitted by applicable law.
California law also provides you with the following rights with respect to your personal information:
Request to Know
The right to know what personal information we have collected, used, disclosed and sold about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom Pentec discloses Personal Information, and the specific pieces of Personal Information Pentec has collected about you. To submit a request to know, you may:
  • Contact Pentec by email at compliance@pentechealth.com or
  • Call Pentec at 800-223-4376.
Please allow up to 30 days for Pentec to process your request.  You may submit such a request once per year.
Request to Correct
The right to request that we correct any personal information we have collected about you. To submit a request for correction, you may:
  • Contact Pentec by email at compliance@pentechealth.com or
  • Call Pentec at 800-223-4376
Request to Disclose
You may have the right to request Pentec to disclose your Personal Information that we collect, use or disclose to third parties.
Contact Pentec by email at compliance@pentechealth.com or
  • Call Pentec at 800-223-4376
  • Request to Delete
You may have the right to request Pentec to delete your Personal Information collected or maintained by Pentec.
  • Contact Pentec by email at compliance@pentechealth.com or
  • Call Pentec at 800-223-4376
Right to Non-Discrimination
You have the right not to receive discriminatory treatment for the exercise of privacy rights conferred by the CCPA.
When you exercise these rights and submit a request to us, we may contact you to provide any additional steps needed to verify your identity and/or the scope of your request. We also may use a third-party verification provider to verify your identity. An authorized agent may submit a request on your behalf. In response to a request submitted by an authorized agent, Pentec may request (i) verification of your identity, and (ii) written proof that you have permitted the authorized agent to act on your behalf.

Response to “Do Not Track” Signals

Some Internet browsers include the ability to transmit “Do Not Track” signals.  Since uniform standards for “Do Not Track” signals have not yet been adopted, Pentec does not process or respond to “Do Not Track” signals.

Updating Your Information

If you wish to stop receiving e-mails or other communications from us, or if you have submitted Personal Information through our Sites and would like that information deleted from our records, please notify us at marketing@pentechealth.com.  

Links to Third Party Websites

Our Sites may contain links to other sites that we believe may offer useful information or services to you. The privacy policies, terms of usage and other conditions of use posted on those sites, and not the policies and procedures we described here, apply to those sites. We are not responsible for the privacy policies or practices of third parties or any of the content of websites linked to our Sites. Your linking to any other websites is at your own risk, and you are responsible for learning about and complying with the privacy policies, terms of usage and other conditions posted on those websites.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time, as permitted by law. We will post the updated Privacy Policy on this page with an updated date. We encourage you to look for updates to this Privacy Policy by checking this date when you access our Sites. Your continued use of our Sites after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms For Additional Information
If you have any questions about this Privacy Policy, the practices of our Sites, or your dealings with our Sites, please contact compliance@pentechealth.com.

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