Privacy Policy

Last Updated Date: 5/01/2023

Aspirtek respects your concerns about privacy. This Privacy Policy (“Policy”)
describes the personal information we may obtain about you, including
when you access our web site online, mobile app, our e-mail, and other
related online and offline services and communications with us (collectively,
the “Sites”). We also describe how we may use and disclose that information,
and explain the choices available to you regarding our use of the
information, the measures we take to protect the security of the
information, and how you can contact us if you have any questions about
our privacy practices.

Please note that the personal information we may obtain in some
circumstances can include “protected health information” (“PHI”), which is
subject to specific privacy and security protections under the Health
Insurance Portability and Accountability Act of 1996 (“HIPAA”).
This Policy and your use of any of our Sites is subject to our Terms Of
Use (“Terms”), and by registering for or otherwise using our Sites, you agree
to be bound by our Terms and this Policy. If you have questions about this
Policy, please contact us as directed below.

1. Information We Obtain
Some of the information we collect is personal information, which generally
means information that identifies you as an individual, or other information
we associate with it. We may obtain personal information in various ways,
such as when you visit our Sites, including at stores, our website, or when
creating a Rite Aid account.

(A) Information We Collect From You

The types of personal information we may obtain directly from you include:

• contact information, such as name, phone number, postal address and
email address;

• demographic information, such as date of birth and gende

• transactional information, such as payment card information (e.g.,
card number, expiration date, and security code), bank account
number, and purchase history;

• information associated with Aspirtek, including credentials, profile
information.

• information related to prescription management (such as medical
information and prescription numbers);

• comments, product reviews and other content provided through or in
connection with our Sites;

• geolocation data associated with your use of the Sites;

• for individuals who apply for a career opportunity with Aspirtek:
contact information, data submitted on a résumé or in a job
application, and other information we obtain to administer the careers
process; and

• for individuals who provide services to Aspirtek: contact information
and other details we may obtain in managing our relationship with
such service providers.

We maintain a database online which may capture information about
consumers, including participation in medical studies.
We also may obtain other information about you in ways we describe at the
time we collect the information or otherwise with your consent.
If you provide us with personal information about any other individual (such
as a family member), you represent that you have any necessary consents to
give us their information for use in accordance with this Policy.

(B) Information We Collect Automatically When you interact with our Sites, we can obtain certain information by automated means (collectively, “Online User Activity”) through cookies, web server logs, web beacons and other similar technologies implemented on
our website and mobile app. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We may use these automated technologies to collect information about
your device (e.g., computer, mobile phone), browsing actions, and usage
patterns. The information we obtain in this manner may include your device
IP address, identifiers associated with your devices, types of devices
connected to our services, web browser characteristics, device
characteristics, language preferences, referring/exit pages, clickstream data,
and dates and times of website visits. These technologies help us (1)
remember your information so you will not have to re-enter it; (2) track and
understand how you use and interact with our products and services; (3)
tailor our Sites around your preferences; (4) measure the usability of our
Sites and the effectiveness of our communications; (5) provide customer
support; and (6) otherwise manage and enhance our Sites and marketing
activities.

Your browser may be configured to alert you when receiving certain types of
cookies or enable you to restrict or disable certain types of cookies. You can
find out how to do this for your particular browser by contacting us in
writing for more information. For mobile devices, you can manage how your
device and browser share certain device data by adjusting the privacy and
security settings on your device. Our Sites are not designed to respond to
“do not track” signals received from browsers. Please note that without
cookies you may not be able to use or benefit from all of the functionality or
features on our Sites.

(C) Third-Party Web Analytics Services
We use third-party web analytics services on our Sites, such as Google
Analytics and Adobe Analytics. The service providers that administer these
services use automated technologies to collect data (such as IP addresses,
cookies, and other device identifiers) to evaluate use of our Sites. To learn
more about Google Analytics and how to opt out of their tool entirely, please
visit www.google.com/analytics/learn/privacy.html.

(D) Online Tracking And Interest-Based Advertising we may use certain cookies known as “Third Party Targeting Cookies” as well as other advertising techniques to share limited identifying information including Online User Activity with advertising partners to provide you with advertising about products and services tailored to your interests. You may
see our ads on other websites or mobile apps through this technique, since it enables us to target our messaging to users considering demographic data, users’ inferred interests and browsing context. In similar fashion, ad technology companies track users’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. This information is used to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites, and to build a profile of users’ online browsing activities. The information collected may include data about users’ visits to websites that participate in the online ad ecosystem, such as the pages or ads viewed and the actions taken on the websites. This data collection takes place both on our Sites and on third party websites that participate in the online ad ecosystem. This process also helps us track the effectiveness of our marketing efforts.

(E) Information we Receive from Third Parties
We may receive information you provide on behalf of third parties, or third
parties provide on your behalf, including but not limited to healthcare
providers and gift card purchasers/recipients. We may receive information
from or about you if you follow or engage with us through social media
platforms that we use. We may also receive information from sources
assisting us with (i) enhancing or correcting our customer records; (ii)
performing marketing and research services; or (iii) detecting fraud or theft.
In the event we acquire a business, we may receive information from the
seller of such business.

2. How We Use the Information We Obtain
We may use the personal information we obtain to:

• provide our products and services, such as to create and manage
Aspirtek customers and loyalty programs, facilitate purchases on our
site, process and fulfill orders, keep you informed about the status of
your orders (including messaging with an Aspirtek professional, who
may provide you with health care information), and provide related
customer and technical support;

• personalize your experience on our Sites, and communicate with you
about products and services that may be of interest to you, including
promotional materials about Aspirtek and third-party products and
services;

• provide and administer your participation in surveys, events, contests
and programs (including discount or coupon-related offers);

• provide you with location-based information 

• operate, evaluate, develop, manage and improve our business
(including operating, administering, analyzing, and improving our
Sites; developing new products and services; managing and
evaluating the effectiveness of our communications; conducting
market research, aggregating and anonymizing data, and performing
data analytics; facilitating the provision of services to Aspirtek; and
performing accounting, auditing, and other internal functions);

• protect against, identify and respond to suspected fraud, criminal
activity, violations of law or our Terms and other policies, or any harm
to our staff or any other individual; and

• comply with and enforce applicable legal requirements, relevant
industry standards, contractual obligations and our policies, including
this Privacy Policy, our HIPAA Notice of Privacy Practices, and our
Terms and Conditions.

We also may use the personal information we obtain in other ways for which
we may provide specific notice at the time of collection or otherwise with
your consent.

3. How We May Share Information
We may share information about you with the following categories of third
parties, where consistent with this Policy and applicable laws:
• Our legal affiliates and agents in connection with our business
operations;

• Our service providers (e.g., IT services, maintenance and hosting of our
Sites, payment processors, marketing and analytics, customer
communications, order fulfillment and shipping), but we only provide
information to these providers to perform their required functions on
our behalf; and

• Third-party brand manufacturers with whom we may partner to
develop programs, and likewise with third parties who provide
services that we offer through our Sites.

We also may disclose information about you in certain unusual
circumstances, including (1) if we are required to do so by law or legal
process; (2) in response to requests by government agencies, such as law
enforcement authorities; (3) to establish, exercise, or defend our legal rights;

(4) when we believe disclosure is necessary or appropriate to prevent
physical or other harm or financial loss; (5) in connection with an
investigation of suspected or actual fraud or other illegal activity; or (6) in the
event we sell or transfer (or contemplate the sale or transfer of) all or a
relevant portion of our business or assets (including in the event of a
merger, acquisition, joint venture, reorganization, divestiture, dissolution, or
liquidation).

4. Links to Other Online Services
Our Sites may provide advertisements for or links to other online services for
your convenience and information, and may include third-party features
such as apps, tools, payment services, widgets and plug-ins (e.g., PayPal,
Facebook, Twitter, Instagram, LinkedIn and YouTube). These third-party
online services and features may operate independently from us. The
privacy practices of the relevant third parties, including details on the
information they may collect about you, is subject to the privacy statements
of these parties, which we strongly suggest you review. To the extent any
linked third-party online service or feature is not owned or controlled by us,
Aspirtek is not responsible for these third parties’ information practices.
You may see us promoted by other businesses on various websites, social
media and other platforms. Please note that we do not always have
complete information about where our brand may be displayed or
promoted, and if you believe that we are featured in venues that are
inappropriate or offensive, please contact us.

5. Your Choices
(A) Choices Available to All Individuals We offer you certain choices in connection with the personal information we obtain about you.

• Accessing and Correcting Your Information: Keeping your information
up-to-date is very important.

• Marketing Emails: From time to time, we or the brand/services
partners we engage with as described above may contact you via
email for the purpose of providing announcements, promotional
offers, alerts, confirmations, surveys, and/or other general
communications. In addition to changing communication preferences
in your account (as noted above), you may unsubscribe from such
marketing communications at any time by selecting the unsubscribe
option within the body of the e-mail. Even if you opt out of receiving
such communications, we will continue sending you non-marketing
email communications, such as administrative or transaction alerts.

• Cookies: As described above, web browsers may offer users the ability
to disable receiving certain types of cookies; however, if cookies are
disabled, some features or functionality of our Services may not
function correctly.

• Targeted Advertising: We may work with advertising partners who
collect information about your online activities and provide you with
choices regarding the use of your browsing behavior for purposes of
targeted advertising. Popular advertising services you may opt out of
targeted advertising from include Google, Facebook, the Network
Advertising Initiative and Digital Advertising Alliance.

(B) Notice Regarding Text Messages We offer service-related and/or promotional messages. If you affirmatively consent to receive these text messages from us and enroll in any text
message program, you will receive updates via text unless you opt-out of the text message program. Message frequency may vary. If at any time you would like to stop receiving text message notifications, please text “STOP” in reply to our message, we will send you a reply message to confirm that you have been unsubscribed and you will no longer receive messages from us. If you want to join again, just sign up as you did the first time and we will start sending messages to you again. If at any time you forget what keywords are
supported, just text “HELP” back to us and we will respond with instructions
on how to use our service as well as how to unsubscribe.

Participating carriers are not liable for delayed or undelivered messages. As
always, message and data rates may apply for any messages sent to you
from us and to us from you. If you have any questions about your text plan
or data plan, it is best to contact your wireless provider. For any questions
about our text program, you can contact us as provided below.

(C) State-Specific Privacy Rights
The residents of certain states are entitled to additional privacy disclosures
and privacy rights. Please see the end of this Policy regarding such
disclosures and to learn more about exercising those rights.

6. How We Protect and Retain Personal Information
We maintain administrative, technical, and physical safeguards designed to
protect personal information against accidental, unlawful, or unauthorized
destruction, loss, alteration, access, disclosure, or use. No data transmission
or storage is 100% secure, and we cannot guarantee that information you
send to us online or via email, or information that we maintain about you,
will not be accessed, disclosed, altered, or destroyed. We will make any
legally required disclosures of any breach of the security, confidentiality, or
integrity of your personal information. To the extent the law of your
jurisdiction allows for notification of a security or privacy incident via e-mail
or the Services, you agree to accept notice in that form.

We retain personal information based on a number of factors, including (i)
for business purposes, for as long as is reasonably necessary to provide you
with our products and services, and for the other purposes we use your
information as described above, and (ii) as reasonably necessary to comply
with our legal obligations, resolve disputes and enforce our agreements. We
may also retain cached or archived copies of your information for a
reasonable period of time.

7. Children’s Personal Information
Our Sites are designed for a general audience and are not directed to
children under the age of 13. We do not knowingly collect or solicit personal
information from children under the age of 18 through our Sites, and
endeavor to promptly delete such information if we become aware of it. If
you believe that a child under the age of 18 may have provided us with
personal information online without parental consent, please contact us.

8. Updates To This Privacy Policy
We may update this Policy from time to time and without prior notice to
you, such as to reflect changes in our personal information practices with
respect to our Sites, or to comply with new privacy laws or best practices.
We will indicate at the top of the Policy when it was most recently updated.
By continuing to use any Sites after such a change, you agree to the
updated Policy.

9. How To Contact Us
Please contact us if you have any questions or requests in regard to this
Policy or our handling of your information, such as to update or correct your
information or preferences, or to submit a request.
You can contact us at: info@asirtekinc.com or fax: 1 (516) 568-5246
You also may write to us at: Attn: Privacy Officer, Aspirtek, Inc., 743 Franklin
avenue, suite#232, garden City, New York 11530.

10. State-Specific Notices
NOTE: Aspirtek is subject to federal privacy laws under HIPAA as described
in the HIPAA Notice of Privacy Practices, and it is therefore not subject to
certain state privacy laws that exempt HIPAA-regulated organizations.
However, we provide consumers with privacy rights that may be exercised
in accordance with our HIPAA Notice of Privacy Practices, and additionally
provide certain access, correction and opt-out services as described in
Section 5 above.

(A) California Residents: Retail Customers
This Section is provided specifically for California residents. In addition to the
disclosures and rights provided above in this Policy, if you are a California
resident you may be entitled to additional information about our practices
as well as the right to exercise certain requests regarding your personal
information.

1. Additional Notice of Collection and Use of Personal Information
This Section elaborates on the disclosures at the top of this Policy in regard
to the categories of personal information we may about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique
personal identifier (such as a device identifier; cookies, beacons, pixel
tags, mobile ad identifiers and similar technology; customer number,
unique pseudonym, or user alias; telephone number and other forms
of persistent or probabilistic identifiers), online identifier, Internet
Protocol address, email address, account name,Social Security
number, driver’s license number, passport number, and other similar
identifiers;

• Additional Data Subject to (Cal. Civ. Code § 1798.80): signature,
physical characteristics or description, state identification card
number, bank account number, credit card number, debit card
number, and other financial information;

• Protected Classifications: characteristics of some protected
classifications under California or federal law, such as race, age,
gender, disability status, and veteran status;

• Commercial Information: commercial information, including records
of products or services purchased, obtained, or considered, and other
purchasing or consuming histories or tendencies;

• Biometric Information: imagery of the face;

• Online Activity: Internet and other electronic network activity
information, including, but not limited to, browsing history, search
history, and information regarding your interaction with websites,
applications or advertisements;

• Geolocation Data;

• Sensory Information: audio and visual information;

• Employment Information: professional or employment-related
information that is typically found on a résumé;

c. Sale or Sharing of Personal Information
We may “sell” to, or “share” with, third parties (as such terms are defined
under applicable state privacy laws) certain (i) Identifiers, (ii) Commercial
Information, (iii) Online Activity, and/or (iv) Inferences, primarily to engage in
online advertising activities and provide tailored content and ads that may
be of interest to you. You have the right to opt out of this disclosure of your
information, as detailed below.

We do not sell or share information about individuals between 13-17 years
old without affirmative authorization to do so, if we have actual knowledge
of the individual’s age. As noted above, we do not knowingly collect or use
information from minors under 18 without parental consent.

d. Disclosure of Personal Information for a Business Purpose
We may have disclosed all of the categories of personal information
described above to affiliates and service providers for a business purpose as
described above.

3. Your Additional Privacy Rights
If you are a California resident you can exercise certain additional rights
regarding your personal information, as described below.
a. Access, Correction and Deletion Rights

• You may request a copy of the following: (1) the categories of personal
information we collected about you; (2) the categories of sources from
which the personal information is collected; (3) the business or
commercial purpose for collecting or selling (if applicable) the
personal information; (4) the categories of third parties with whom we
shared personal information, and the categories of personal
information shared; and (5) the specific pieces of your personal
information that we have collected, used, disclosed, or sold.

• You may request that we (and our service providers) correct your
personal information if it is inaccurate or delete your personal
information. Note that deletion requests are subject to certain
limitations, for example, we may retain personal information as
permitted by law, such as for tax or other record keeping purposes, to
maintain an active account, to process transactions and facilitate
customer requests, and for certain other internal business purposes
described in our Policy. Before submitting any request, please note the following important information:

• You may directly access much of your personal information if you have
submitted a NCND with us, accessing our web page, and or receiving
Information on Aspirtek.

• If you are submitting a deletion request, your information will be
permanently terminated and personal information on our data base
will be deleted consistent with any applicable laws. To the extent we
are able to link the information in your request to our marketing
programs (e.g., email and text subscriptions), we will remove you from
those programs, but depending on how you enrolled in those
programs you may need to separately opt-out of them. 

b. Opt-Out Rights
You have the right at any time to opt out of (i) any selling or sharing of your
personal information to a third party (excluding service providers or other
exceptions permitted by law); (ii) any third-party targeted advertising (i.e.,
cross-context behavioral advertising); and (iii) any use of sensitive personal
information (such as precise geo-location or financial information) except for
the purposes it was collected and as otherwise permitted by law. As
described above, certain identifying information with Online User Activity
may be shared with brands/services we partner with, advertising businesses
and other third parties through Third Party Targeting Cookies or other
means. You are entitled to opt-out of these and other activities (some of
which are referred to as a “Do Not Sell” right):

• Any selling or sharing of your personal information to a third party
(excluding service providers or other exceptions permitted by law);

• Any third-party targeted advertising (i.e., cross-context behavioral
advertising); and

• Any use of sensitive personal information (such as precise geo-location
information) except for the purposes it was collected and as otherwise
permitted by law.

As described above, you can opt-out of Third Party Targeting Cookies by as
described above or the used of an automated GPC signal from your browser.
All other opt-opts can be exercised as provided below.

Privacy laws may provide you with other opt-out rights which are
inapplicable to us. In particular, we do not engage in impactful profiling
activities with respect to our customers.

c. Verifying and Processing Requests
To help protect your privacy and maintain security, we will take steps to
verify your identity before granting you access to your personal information
or complying with your request. You will be required to provide some
information, based on the nature of your request, including, but not limited
to: name, email, home address, date of birth, phone number. If you ask us to
provide you with specific pieces of personal information, we will require you
to sign a declaration under penalty of perjury that you are the consumer
whose personal information is the subject of the request. If you designate an
authorized agent to submit a request on your behalf (a) we may require you
to provide the authorized agent written permission to do so, and (b) we may
require you to verify your own identity directly with us as described above.
If we deny a privacy request, you may appeal the decision to us through the
contact information. To the extent possible, please describe the basis for
your appeal and if there is any specific personal information that concern
you. We will endeavor to provide a prompt response.

We may not, and will not, discriminate against any customer for exercising
their privacy rights, including those provided by the applicable privacy laws.
Please note that we may otherwise continue to share your personal
information with our affiliates and service providers, and as otherwise
directed by you, for the purposes described in our Policy.

11. Additional Disclosures
We may also send consumers marketing and promotional communications
(such as by email, text or through our mobile app) Aspirtek does not generally assign monetary value to consumers’ personal information, and promotions associated with our products. To the extent privacy laws requires that a value be assigned to such programs, or to the price or service differences they involve, the Points, additional savings,
discounts, exclusive pricing, and promotional offers made available in
connection with the Rewards Program are reasonably related to the value
provided to Aspirtek by your personal information. 

(B) California Residents: Non-Retail Customers
Privacy rights apply to all individuals (not just customers), including job
applicants, current and former employees, contractors and business
partners. Due to the nature of these relationships, the collection and use of
personal information can vary, but in general terms and in addition to all the
disclosures above:

• Job applicants may provide us with personal information as part of an
employment application and review process that includes the
applicant’s contact information, education and employment history,
resume and cover letter. We do not use this information for any
purpose other than to evaluate the individual for employment with us
and manage our careers program. Job applicants may provide
additional information for routine background checks to a third-party
provider of such services, under specific privacy terms and consents
that will be provided at the time of collection.

• Employees receive information that provides additional details
regarding our employee privacy practices.

• We collect contact information and other personal information
reasonably necessary to engage with contractors and business
partners in the course of a business relationship.

All such individuals who are California residents can request additional
information about our privacy practices with respect to their information.
Please provide sufficient information that we can identify you, and be aware
that we may employ a more extensive authentication process to verify your
identity before responding to your request. If you have any questions about
the notices or rights above, or our privacy practices as they are relevant to
you, please contact us.

(C) Residents of Nevada Only
For Nevada residents, please note that we do not sell personal information
as defined by Nevada law (Nevada Revised Statutes, Chapter 603A, Section
1.6). You can submit a request to us regarding the sale of such information as
directed by the contact information provided above.

12. International Data Transfers And Use
Our Sites are controlled and operated by us from the United States and are
not intended to subject us to the laws or jurisdiction of any state, country or
territory other than those of the United States. Any information you provide
through use of the Sites may be stored and processed, transferred between
and accessed from the United States and other countries which may not
guarantee the same level of protection of personal information as the one in
which you reside. However, we will handle your personal information in
accordance with this Policy regardless of where your personal information is
stored or accessed.