Privacy Policy

Our privacy policy explains how information is collected, used and disclosed by Tricella, Inc. (“we”, “us”) with respect to your access and use of Tricella’s services, whether through our website (located at www.tricella.com) or Tricella’s mobile applications (referred to below as “Pillbox” or “Tricella Pillbox”). When we use the term “Personal Information” in this document, we mean any information that can be used to contact or identify you (such as your name or email address, or your medication list in combination with other information that identifies you).

IS REGISTRATION NECESSARY?

Registration is not required to use Pillbox, however registering does enable you to access your account information on multiple devices. Registering also enables you to recover your information in the event you change mobile phones or reinstall the application on your mobile device. We are not responsible for the use of any Personal Information that you may decide to provide to any Benefit or Healthcare Provider in connection with the use of Tricella Pillbox or the program overall.

We do require you to register if you intend to use certain features such as but not limited to, pill reminder, missed pill alerts, wrong pill alerts and caregiver interactions.

WHAT INFORMATION DO WE COLLECT?

If you complete our registration process we may collect Personal Information from you, such as your name, email address and phone number, as well as certain non-identifying information, like information related to medications or supplements you are taking and your individual preferences.

We also collect and store any content that you upload, download or access via Tricella Pillbox, which may include Personal Information about you (including pictures of your prescription or over the counter medication that you decide to upload).

We may automatically collect certain information when you use Tricella Pillbox, such as Internet Protocol (IP) address (if using a browser), operating system, the browser type, the address of a referring site and your activity on Tricella. This information is not treated as Personal Information unless we combine it with or link it to any of the personally identifiable information mentioned above. As with many other sites, we may also use “cookies” or web beacons. These are small files that your browser places on your computer. We may use both session cookies and persistent cookies to better understand how you interact with our services, to monitor aggregate usage by our users and web traffic routing on our services, and to improve our services. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. In addition, some third parties that we work with (e.g. Kiss Metrics and other technologies used to evaluate the effectiveness of marketing programs) may use their proprietary technologies to analyze your use of Tricella Pillbox. Note that this Privacy Policy covers only the use of cookies and other similar technologies by us, and does not cover the use of third-party technologies.

HOW DO WE USE THE INFORMATION WE COLLECT?

We use the information collected through Tricella Pillbox (including Personal Information) for the following purposes:

  • to provide our services, including by providing information such as drug or supplement reminders or drug interactions;
  • to respond to your emails, submissions, questions, comments, requests, and complaints and provide customer service;
  • to monitor and analyze usage and trends, and to increase the functionality and user friendliness of our services;
  • to provide content or features that match your profile or interests, including advertisements and other marketing material; for instance, if you have entered a drug associated with hypertension, we may send you information regarding hypertension and or recommendations of additional products and services related to hypertension;
  • to send you confirmations, updates, security alerts, administrative messages and otherwise facilitate your use of, and our administration and operation of, our services;
  • and for any other purpose that is communicated to you when we collect the information.

We may receive remuneration from third parties for communicating with your about their products or services, or for providing you with promotional items from them.

WHAT INFORMATION DO WE SHARE WITH THIRD PARTIES?

We will not share the Personal Information we have collected from you, except as described below:

  • we may share your information, including Personal Information, with service providers who have a contractual relationship with us in connection with the operation of our site or our services (these service providers have access to your Personal Information only to perform services on our behalf and are obligated not to disclose it or use it for any other purposes);
  • we may share aggregated information with third parties for industry analysis, demographic profiling and other similar purposes;
  • when you give us your consent to do so, including if we notify you that the information you provide will be shared in a particular manner and you provide such information;
  • when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests or legal authorities, including responding to lawful subpoenas, warrants or court orders;
  • to enforce or apply our privacy policy, our terms of use or our other policies or agreements, and to investigate misuse of our systems;
  • and in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where Personal Information may be disclosed or transferred as one of our business assets.

We may receive remuneration from third parties for sharing your Personal Information with them in the circumstances described above.

We are not responsible for the actions of service providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties.

LINKS TO OTHER SITES OR APPLICATIONS

Tricella Pillbox may contain links to other sites or applications. Any information you provide on those sites or applications is provided directly to the owner of that site or application and is subject to that party’s privacy policy. Our privacy policy does not apply to such sites, and we are not responsible for the content or privacy and security practices and policies of those sites.

IS MY PERSONAL INFORMATION PROTECTED BY HIPAA?

The Personal Information that you enter into our system is not protected by HIPAA (the Health Insurance Portability and Accountability Act of 1996). HIPAA protects health information held by or on behalf of your health care provider or health plan. When you enter Personal Information into Tricella Pillbox we hold it on our own account. WHAT STEPS DO WE TAKE TO PROTECT YOUR INFORMATION ONLINE?

We are very concerned with safeguarding your information and employ reasonable measures to do that. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

ACCESSING AND MODIFYING YOUR INFORMATION

If you have an account, you can access and modify the Personal Information (that you provided to us) that is associated with your account. You may “opt out” of receiving marketing or promotional emails or other messages from us by changing your account preferences or by following the instructions in those messages. Note that, even if you opt out of these communications, you may still receive messages from us regarding the administration of your Account and your use of our services.

Whether you are a registered or unregistered Tricella Pillbox user, you can request to delete your Personal Information. If you are an unregistered Tricella Pillbox user, you may send us an email with the subject heading “Delete My Data”. If you are a registered user you can request to delete your Personal Information you have made available by contacting us and requesting that your Account be deleted. We will take steps to delete your Personal Information as soon as is practicable, but some information may remain in archived/backup copies for our records and as otherwise required by law.

Please note that if you decide to have your Personal Information deleted, Tricella may retain any data related to your Tricella Pillbox history in aggregate form, and use and share such aggregate data for its business purposes. Please also note that if you delete our app from your mobile device, we may retain the Personal Information and content in your account, in case you want to reactivate your account at some point in the future.

INTERNATIONAL USERS

If you are located outside the United States and choose to provide information to us, we may transfer your information to the United States and process it there (or any other country where we operate). By using Tricella Pillbox, you consent to the collection, transfer, use, storage and disclosure of your information as described in this privacy policy.

OUR POLICY TOWARD CHILDREN

The Services are aimed at a general audience and are not directed to children under 13. Our data collection and use practices adhere to the United States Children’s Online Privacy Protection Act (COPPA). We will not knowingly collect personal information directly from children under 13 years old without parental consent. If we become aware that we have collected personal information directly from a child under 13 years old (without the necessary parental consent), we will make an effort to delete the personal information provided by the child.

CHANGES

Any information that is collected is subject to the privacy policy in effect at the time such information is collected. We may, however, modify and revise our privacy policy from time-to-time. If we make any material changes to this policy, we will notify you of such changes by posting them on Tricella website or by sending you an email or other notification or message (including push notifications and in-app news notices), and we will indicate when such changes will become effective. By continuing to access or use Tricella Pillbox after those changes become effective, you are agreeing to be bound by the revised policy.

QUESTIONS?

Please contact us if you have any questions about our privacy policy.

Effective: December 18, 2015