Last Updated: March 18, 2025
This consumer health data privacy notice (“Health Data Notice”) supplements the Privacy Policy of Wellgistics Tech & Hub, LLC (formerly Alliance Pharma Solutions, LLC) and Wellgistics Pharmacy (formerly Community Specialty Pharmacy, LLC), d/b/a Wellgistics Hub (“Wellgistics” “we,” or “us”) and applies to personal data defined as “consumer health data” subject to the Washington State My Health My Data Act (MHMDA) that we collect from our websites, including without limitation those located at https://wellgistics.com/; https://wellgisticsrx.com/; https://wellgisticshub.com/; and https://wellgisticshealth.com (the “Websites”) and our mobile and/or other interactive application (“App(s)”, along with the Websites are collectively, the “Platform”). Your access and use of the Platform, any part thereof, or anything associated therewith, including its content (“Content”), any products or services provided through the Platform or otherwise by Wellgistics, and any affiliated website, software or application owned or operated by Wellgistics (collectively, including the Platform and the Content, the “Service”) are subject to this notice unless specifically stated otherwise. Capitalized terms not otherwise defined in this Privacy Policy have the same meaning as set forth in the Wellgistics Terms and Conditions (“Terms and Conditions”).
This Health Data Notice describes the following:
- The categories of consumer health data collected by Wellgistics;
- How we use the consumer health data;
- With whom we share the consumer health data; and
- How consumers can withdraw consent from future collection or sharing of their health data.
Categories of Consumer Health Data Collected
We collect any information you provide (or consent your authorized third parties such as health care providers and Pharmacies to provide) when you use the Service, as well as some information automatically based on your use of the Service, including, but not limited to:
- Prescription information, including without limitation, the following: the specific drugs prescribed, the quantity of the drugs prescribed, the dosage of the drugs prescribed, the number of refills of the drugs prescribed, the applicable health care providers, and diagnostic codes
- Pharmacies where prescriptions are transferred to and the cost of prescriptions
- Usage activity concerning your interactions with the Service and/or third-party websites, networks or applications accessed through the Service
- Statements or content (e.g., comments, videos, photographs, images) and information about such statements or content, which you submit or publish on or through the Service or which are accessed via your public or linked social media pages (e.g., Facebook, Twitter, Instagram)
- Any other information you provide when you contact or communicate with us
We also collect certain medical information on behalf of the Pharmacies, which may include, but is not limited to health and medical data related to your prescriptions sent to Wellgistics and communications with health care providers and/or Pharmacies.
If you or a third party sends Wellgistics a comment, message or other communication (such as, by way of example only, email, letter, fax, phone call, text message, chat message or voice message) about you or your activities on or through the Websites and/or the Apps, then Wellgistics may collect any health information provided therein or therewith.
We may also receive information from third parties that pay for your care or provide you with treatment, laboratory care or prescription medication, which may include, for example, your prescription history and laboratory test results.
It is possible to make inferences about consumers based on their browsing history on our Platform. We may learn about our website visitors’ and customers’ health if they answer an online survey or questionnaire. We may learn health-related information if it is offered to us voluntarily when a user contacts us via email, phone or chat (as applicable). We learn about health-related preferences based on online behavioral advertising collected with tracking technologies. Please see our Privacy Policy for more information about our use of tracking technologies.
How We Use The Consumer Health Data
We use the health data we collect for a number of purposes, including, but not limited to:
- Administering your account;
- Fulfilling your requests;
- Facilitating your movement through the Service;
- Facilitating your use of the Service and/or products or services offered through the Service;
- Communicating with you by letter, email, text, telephone or other forms of communication;
- Providing you with information about Wellgistics and the Pharmacies and/or their respective businesses, products and services by letter, email, text, telephone or other forms of communication;
- Providing you with customer support;
- Providing you with information about third-party businesses, products and services by letter, email, text, telephone or other forms of communication;
- Analyzing user behavior and activity on or through the Service;
- Conducting research and measurement activities for purposes of product and service research and development and other activities related to Wellgistics, the Service or products and services offered via the Service;
- Placing and tracking orders for products or services on your behalf;
- When required by applicable law, court order or other governmental authority (including, without limitation and by way of example only, in response to a subpoena or other legal process); or
- Wellgistics believes in good faith that such use is otherwise necessary or advisable.
We may de-identify or anonymize your information and use, create and sell such de-identified or anonymized information, or any business or other purpose not prohibited by applicable law.
With Whom We Share The Consumer Health Data
We may disclose your information to third parties in connection with the provision of our Service or as otherwise permitted or required by law. For example, we may disclose your information to:
- Our affiliates in order to provide our services to you, including Wellgistics Health, Inc. and Wellgistics Distribution, LLC;
- Our third-party and service providers (collectively “vendors”) that provide services to enable us to provide the Service, to run our business and administrative operations, and to enable us to promote and advertise the Service and the products and/or services offered via the Service;
- The Pharmacies to enable them to provide services to you via the Service and to collect payment on their behalf;
- To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock with such third party (where in such instances, the disclosure may include a transfer and sale of your information);
- To a third party in the event we believe it necessary or appropriate to comply with a legal obligation, when we believe in good faith that the law requires it, at the request of governmental authorities conducting an investigation, to verify or enforce our agreements, terms of use, or other applicable policies, to respond to an emergency, or otherwise to protect the rights, property, safety, or security of third parties, visitors to our website, or the public.
- To any third party where you have provided your consent, including social networking sites such as Facebook, Instagram, or Twitter. If you agree to have your personal information shared with a third party, your personal information will be disclosed to the third party and will be subject to the privacy policy and business practices of that third party.
How Consumers Can Withdraw Consent From Future Collection or Sharing of Their Health Data
You have specific rights with respect to your consumer health data:
- You have the right to know if we are collecting, using or disclosing your consumer health data, to access that data, and to receive a list of the affiliates and the categories of third parties with whom we have shared your information.
- If we are processing your consumer health data with your consent, you have the right to withdraw that consent.
- You have the right to request that we delete your consumer health data.
We will do our best to honor your requests subject to any legal and contractual obligations. We will not discriminate against you for exercising any of your rights.
To exercise your rights, you can contact us or otherwise communicate your request by emailing us at [email protected].
We will authenticate your request and process it as required by law. Please allow 45 days for a response. If we deny your request, you may appeal that denial by requesting a review of the decision via email to [email protected].