By accessing and using the Web Site after the notification banner or message appears on the Web Site, and any subsequent times thereafter, you expressly agree to the terms of this Privacy Statement and consent to the collection and use of your information as set forth herein. If you do not agree to this Privacy Statement, you are not authorized to access the Web Site or use any of its features and must immediately discontinue use of the Web Site. The terms “we,” “us,” and “our” refer to AmerisourceBergen, and the terms “you” and “yours” refer to you, as user of the Web Site. By accessing and using the Web Site, you also agree to the Terms and Conditions.
Types of Users
This Privacy Statement applies to the following categories of users. You may fall into one or more of these categories depending upon your usage of the Web Site and your relationship with AmerisourceBergen.
- Suppliers. This category includes users that interact with the Web Site in their capacity as vendors (or prospective vendors) of products or services to AmerisourceBergen.
- Customers. This category includes users that interact with the Web Site in their capacity as purchasers of products or services from AmerisourceBergen.
- Children. This category includes any user that is under the age of 18.
- Visitors. This category includes any user that is not a Supplier, Customer, or Child.
Personal Data that is attributable to users in these categories may be referred to within this Privacy Statement as Supplier Data, Customer Data, Child Data, or Visitor Data, respectively.
Protection of Children
AmerisourceBergen will not knowingly collect, use or disclose Personal Data from a Child without obtaining prior consent from a person with parental responsibility (parent or guardian). AmerisourceBergen abides by laws protecting the privacy of Children. Should a user whom we know to be under 18 provide Personal Data to us, we will use that information only to respond directly to that Child to inform him or her that we must have parental consent before receiving information about him or her and then delete it.
Collection and Use of Your Information
The amount and type of information we collect depends on how you use the Web Site. AmerisourceBergen may collect information about you from a variety of sources, including (a) information you provide directly; (b) information we collect about you when you visit the Web Site, use our services, or view our online advertisements; and (c) information we receive from other sources. Any or all of these types of information may include “Personal Data,” which means any information relating to an identified or identifiable natural person, where an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Information We Collect Directly From You
We may collect information directly from you when you visit the Web Site, choose to use services or participate in programs or otherwise provide information directly to us. Information we collect directly from you may include: your user ID and password; name, email address, postal address, and/or telephone number; payment details; information about you such as date of birth, gender and other demographic information; product and service preferences and/or behaviors; and future communication preferences. We may use Personal Data that we collect directly from you to:
fulfill our obligations arising from any contracts entered between you and us and providing you with the information, product and service you request;
- provide you with other services that we have offered to you;
- create and manage your account;
- develop and provide advertising tailored to your interests;
- send you service-related communications; or
- ensure that content from the Web Site is presented in the most effective way for you and your computer.
Information We Collect About You
We may automatically collect information about you when you visit the Web Site, use our services, or view online advertisements. We may log data or use tracking technologies such as cookies and web beacons to collect this information about you. This information includes technical information about your device and network access, including: your IP address, browser type and version, browser plug-in types and versions, operating system and platform; device-specific information, such as time zone setting and mobile network information (including location information); and other information about your visit, such as the webpages you view, links you click, language preferences, websites you visited before coming to the Web Site, page response times, download errors, page interaction information (such as lengths of visits to certain pages, scrolling, clicks and mouse-overs), or your destination when you leave the Web Site. We may use Personal Data that we collect about you to:
- administer and improve the Web Site, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- analyze the use of our products and services;
- measure the effectiveness of the advertising we serve to you and others; or
- make suggestions and recommendations to you and other users of the Web Site about goods and/or services that may interest you or them.
Information We Receive From Other Sources
We work closely with certain third parties (including, for example, our affiliates, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, public websites, public agencies, market research companies, and other contractors or consultants) and may receive information about you from them. Please be advised that any information provided to us by a third party may also be subject to that third party’s Privacy Statement. We may use Personal Data we receive from other sources, in combination with information we collect either directly from you or about you, for the same purposes as we use the information we collect either directly from you or about you.
Legal Basis Under EU General Data Protection Regulation for Processing Personal Data of EU Residents
Where you have consented to data processing, your consent provides the legal basis to process your Personal Data (as defined above). You have the right to withdraw consent at any time. Please note that your withdrawal of consent to collect and process your Personal Data will not affect the lawfulness of processing your Personal Data based on your consent before you withdrew your consent. We may also process your Personal Data on the basis of contractual necessity to perform a contract we have with you. We may also process your Personal Data on the basis of our legitimate interests, including in providing and improving our services. For example, AmerisourceBergen has a legitimate interest in understanding your login history so we can assess your interaction with our services. We also have a legitimate interest in providing and developing interesting features to provide to our users. Where we rely on legitimate interests to process your Personal Data, you have the right to object to such processing (meaning that you can ask us to stop). You can use your privacy settings to control certain ways in which we process your Personal Data. You can also contact us, using the details below, to object to other forms of processing.
We may use information we collect to directly market AmerisourceBergen services and products to you in your capacity as a Supplier, Customer or Visitor unless:
- You have opted out of this use of your Personal Information in accordance with this Privacy Statement; or
- AmerisourceBergen has reason to know that you are in the European Union and have not opted in to this use of your Personal Information.
Except as prohibited in this Privacy Notice or our Terms and Conditions, AmerisourceBergen or a third-party service provider we select may serve ads according to information we collect during your visits to any AmerisourceBergen website, including the Web Site. AmerisourceBergen will (i) where legally required, provide you with such information only after you have opted in and (ii) provide you the opportunity to opt out if you do not want to receive further marketing-related types of communication from us. You can opt out of these at any time.
Sharing Your Information
Sharing Information With AmerisourceBergen Affiliates
Sharing Information With Service Providers
We may share information (including Personal Data) either that we collect directly from you or that we collect about you with certain third-party service providers to perform a variety of services on our behalf. These service providers include business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, advertisers and advertising networks for selecting and serving relevant adverts to you and others, and analytics and search engine providers for assisting us in the administration and improvement of the Web Site. Please note that we provide our service providers with only that Personal Data which is necessary for them to perform services for us and contractually restrict their use to those purposes. There also may be instances where AmerisourceBergen may share information (including Personal Data) with third parties who have not been retained by us (directly or indirectly). For example, we may make such a disclosure: as required by applicable law, court order or governmental regulation; if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding here or abroad; in order to enforce or apply our Terms and Conditions or other agreements; or to protect the rights, property or safety of AmerisourceBergen or our customers. Information we collect (including Personal Data) also may be transferred to a third party in the event that AmerisourceBergen or a part of it is sold, assigned or transferred, or as part of the process of considering such a transaction, in which case we will use reasonable endeavors to ensure the actual or proposed buyer, assignee or transferee treats your information in accordance with this Privacy Statement.
Our Use of Certain Third-Party Services
Use of Google Analytics
To better serve you and other potential customers, AmerisourceBergen has implemented Google Analytics Advertising features such as, but not limited to, Google Analytics Demographics and Interest Reporting. Using the Google Ad settings, you can opt out of Google Analytics Advertising. AmerisourceBergen will not merge your Personal Data with non-Personal Data collected through any Google Analytics Advertising features unless we provide you notice and obtain your affirmative (i.e., opt-in) consent prior to that merger. We and third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to the Web Site. We and third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to your visits to the Web Site. We may use data from Google’s Interest-based advertising or third-party audience data (such as age, gender and interests) with Google Analytics primarily to improve our marketing campaigns and the Web Site’s content. For more details on how AmerisourceBergen uses Google Analytics to collect and process data, please visit Google Analytics’ Terms of Service at https://marketingplatform.google.com/about/analytics/terms/us/ (Note: this is an independent website not sponsored by or affiliated with AmerisourceBergen).
Use of Google Maps API
To the extent AmerisourceBergen develops and implements Google Maps API (“Google Maps”) in connection with the Web Site, and such implementation of Google Maps enables AmerisourceBergen to gain access to your information in connection with your use of Google Maps, including Personal Data or non-Personal Data usage information (such as location), AmerisourceBergen will use and retain such information in accordance with this Privacy Statement. This Privacy Statement constitutes AmerisourceBergen’s notification to you of the type(s) of data that it intends to collect from you or your device when you use Google Maps. AmerisourceBergen’s implementation of Google Maps in connection with the Web Site will not obtain or cache your location in any manner unless we obtain your prior consent, which you may revoke at any time. For more information regarding Google’s privacy policies in connection with Google Maps, please visit Google’s Privacy Statement at http://www.google.com/policies/privacy (Note: this is an independent website not sponsored by or affiliated with AmerisourceBergen).
To the extent you are located in the European Union, AmerisourceBergen will comply with Google’s EU User Consent Policy, available at: http://www.google.com/about/company/user-consent-policy.html (Note: this is an independent website not sponsored by or affiliated with AmerisourceBergen).
Updating and Accessing Your Information
We encourage you to update the information that you provide to us, such as providing us with a new mailing or e-mail address. This will help us continue to provide information to you that best meets your needs. In addition, AmerisourceBergen complies with laws and regulations applicable to certain rights that permit access or amendments to your data in our files, including, but not limited to, the European Union General Data Protection Regulation (the “GDPR”). Depending on the jurisdiction in which you live, you may have rights to access, correct, delete, or transfer your information. Under the GDPR, insofar as it applies to your use of the Web Site, you have the following rights:
- Right of access. You have a right of access to any Personal Data we hold about you. You can ask us for a copy of your Personal Data; confirmation as to whether your Personal Data is being used by us; details about how and why it is being used; and details of the safeguards in place if we transfer your information outside of the United Kingdom or the European Economic Area (“EEA”).
- Right to update your information. You have a right to request an update to any of your Personal Data that is out of date or incorrect.
- Right to delete your information. You have a right to ask us to delete any Personal Data that we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details below. We will pass your request on to other recipients of your Personal Data unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, using the contact details below.
- Right to restrict use of your information. You have a right to ask us to restrict the way that we process your Personal Data in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the contact details below. We will pass your request on to other recipients of your Personal Data unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details below.
- Right to stop marketing. You have a right to ask us to stop using your Personal Data for direct marketing purposes. If you exercise this right, we will stop using your Personal Data for this purpose.
- Right to data portability. You have a right to ask us to provide your Personal Data to a third-party provider of services. This right applies only where we use your Personal Data on the basis of your consent or performance of a contract, and where our use of your information is carried out by automated means.
- Right to object. You have a right to ask us to consider any valid objections you have to our use of your Personal Data where we process your Personal Data on the basis of our or another person’s legitimate interest.
You may exercise these rights by contacting AmerisourceBergen under the “Contact Us” section below. In order to protect your data from unauthorized access or alteration by third parties, all requests to update, access, correct, delete, or transfer your information will be subject to verification of the identity of the requesting individual.
If you have any concerns or questions about this Privacy Statement, and the privacy practices set forth herein, including your dealings with the Web Site, please contact us directly as follows:
227 Washington Street
Conshohocken, PA 19428
Attention: Sheila Hawes, Chief Privacy Officer
Sheila Hawes is our Chief Privacy Officer; Umesh Yerram is our Data Protection Officer for all regulatory purposes related to GDPR.
The Data Protection Officer and the Chief Privacy Officer may also be contacted at email@example.com.
Lodging a Complaint
Depending on the jurisdiction in which you live, if you believe that we are not processing your Personal Data in accordance with the requirements set forth in this Privacy Statement or applicable data protection laws (e.g., GDPR), you may have the right to lodge a complaint with a supervisory authority regarding this Privacy Statement.
You acknowledge that the Internet is a global environment and your use of Internet data can involve the collection, processing and transmission of data on an international basis. As described above, we may share your information with third parties and with AmerisourceBergen subsidiaries and affiliates, which may be located in, or use technology, equipment, products and services located in, countries different from that in which your information is located or stored. Where this is the case, we will take reasonable steps to ensure that your information receives the necessary level of protection and comply with applicable law, including, but not limited to, the GDPR.
Any transfer of Personal Data between AmerisourceBergen’s European Union affiliates, subsidiaries and services providers and AmerisourceBergen’s U.S.-based operations (or the operations of its service providers) for processing in the United States is conducted pursuant to established transfer mechanisms such as the European Commission’s Standard Contractual Clauses. You may contact us using the details below to obtain information regarding the safeguards we use to transfer Personal Data outside of the European Economic Area (“EEA”).
By accessing and using the Web Site and communicating electronically with us, you acknowledge and agree that your data may be transferred in accordance with this Data Transfer section.
Security of Your Information
We use appropriate technical, administrative and physical safeguards to protect data that pertains to you from loss, misuse or alteration. You acknowledge and agree that no organization can guarantee the absolute security of Personal Data, and any transmission of Personal Data is at your own risk. Although AmerisourceBergen makes a genuine effort to ensure the security of information and transactions conducted on the Web Site, it cannot and does not guarantee communications and transactions conducted online will be secure. You acknowledge this and that system failures may limit your ability to use the online services. You agree to assume all risk and liability arising from your use of AmerisourceBergen’s online services, including the risk posed by any breach in the security of communications and transactions you conduct with AmerisourceBergen online.
You are solely responsible for maintaining the confidentiality of your password and any other login credentials related to your account, and agree AmerisourceBergen will have no obligation with regard to them. You agree to notify AmerisourceBergen immediately if you become aware of any unauthorized use of your account or any other breach of security related to your account. You acknowledge and agree that you are also entirely responsible for any and all activities that occur under your account, with or without your permission, and that you may not use anyone else’s account at any time with or without the permission of the account holder. AmerisourceBergen will not be liable for any loss that you may incur as a result of unauthorized access to any user’s account. However, you may be held liable for losses incurred by AmerisourceBergen or another party due to someone else using your account or password. AmerisourceBergen reserves the right to terminate accounts for failure to satisfy these terms.
Links to Other Sites
This Privacy Statement applies only to the Web Site and not to third-party websites. We may provide links to other websites. We strive to link to third-party websites that meet a high set of standards. However, we cannot guarantee the privacy standards of such third-party websites to which we link or be responsible for the contents of sites other than the Web Site. This Privacy Statement is not intended nor should it be construed to be applicable to any linked non-AmerisourceBergen site.
Modifications and Updates to Privacy Statement
This Privacy Statement becomes effective on January 1, 2020. AmerisourceBergen may update and modify this Privacy Statement at any time and from time to time, and such updates and modifications will be effective immediately upon posting the updated or modified Privacy Statement. You agree to review this Privacy Statement periodically to be aware of such updates and modifications and your continued access or use of the Web Site after any updates and modifications will be deemed your conclusive acceptance of the updated or modified Privacy Statement.
Cookies, Web Beacons and Other Technologies
© Copyright AmerisourceBergen Corporation – January 2020.