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Privacy Promise

Specialty Benefit Services Privacy Promise

Version 2.0. Last Revised: 03/15/2013

This Privacy Promise is provided by Express Scripts Holding Company (“ESRX”, “we”, “us” or “our”) to all visitors (“you” or “your”) who use the available pages of the Specialty Benefit Services website located at http://www.SpecialtyBenefitServices.com (the “Site”). The Site may be accessed via the World Wide Web or through a hyperlink embedded in an e-mail. This Site is provided to you as a service to provide information regarding our comprehensive approach to managing total specialty drug spend and enhancing patient care.

We are firmly committed to protecting the confidentiality of your Personal Information. The term “Personal Information” means any information which can be used to identify you including by way of example, but not limitation, name, date of birth, mailing address, phone number, cell phone number, e-mail address, credit card information, and/or Social Security number.

Collection and Use of Non-Personal Information

How We Collect Non-Personal Information

General Tracking Information

When you visit the Site, we may collect Non-Personal Information from you. "Non-Personal Information" means a data element or collection of data elements that by itself cannot be associated with a specific individual. Non-Personal Information includes, by way of example but not limitation, the Internet browser or computer operating system you are using, your IP address or the automatic tracking of the pages of this Site that you access, and Site data collected on an aggregated, anonymous basis through web server logs and cookie technology (further described below), third-party ad servers, and clear GIFs. Our web server automatically collects this information, including your IP address, when you request pages from our server. We may also collect other information regarding your interactions with the Site.

Cookies

We may utilize a standard technology called “cookies” and web server logs to collect information about how our Site is used. A cookie is a very small text file, which often includes an anonymous unique identifier. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, the time spent at our Site, and the websites visited immediately prior to and after visiting our Site. When you visit the Site, the Site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it. With most Internet browsers, you can erase cookies from your hard drive, block all cookies, or receive a warning before a cookie is stored. Please refer to your browser's instructions or online help files to learn more about these functions.

How We Use Non-Personal Information

We may use two kinds of cookies – session ID cookies and persistent cookies. Session ID cookies are used to personalize your user experience, to determine ways to improve our Site, Site content, and the services offered through the Site. These cookies are deleted from your hard drive when you close your browser session. Persistent cookies are used to collect non-personally identifiable information such as Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, platform type, date/time stamp and number of clicks.

We use your IP address so that we can send data (such as the web pages you request) to you. We may aggregate this data with data on the pages visited by other users to track overall visitor traffic patterns to help us understand how you use the Site and your preferred and most frequently used Site pages and services, and to provide you with better service connections and improved Site use and functionality. We may analyze utilization information in the aggregate for our internal purposes. We will not sell or disclose your Non-Personal Information to other companies or organizations.

We may perform statistical analyses of the traffic patterns, Site usage and behaviors associated with our Site. We may use these analyses to generate Aggregate Data from the original Non-Personal Information. “Aggregate Data” is summary level data, such as the number of users in a specific gender in a specific zip code. Aggregate Data does not contain information that can be used to identify or contact you, such as your name, address, telephone number or e-mail address, and does not reflect the original form of the Non-Personal Information collected from you. We may sell or disclose the Aggregate Data to other companies or organizations, and we may engage third parties who operate a Linked Site to collect Non-Personal Information from users of that Linked Site and share that Non-Personal Information with us as part of services provided on our behalf. Linked Site providers will not have the ability to translate the Non-Personal Information they collect for us into Personal Information. Please see our Linking Policy below for more details. In some cases, we may share Non-Personal Information with third parties who provide services to us.

Collection and Use of Personal Information

How We Collect Your Personal Information

E-mails Sent to Us

Sending e-mails to us is optional and is not necessary to access the Site; however, users who send us e-mails with comments and questions may be provided with appropriate response and additional information that may be of interest.

Faxes Sent to Us

Any fax forms obtained through the Site, completed with information provided by the user, and faxed in accordance with the instructions on the fax forms are not subject to this Privacy Promise and the correspondence Terms of Use. Rather, these faxes are subject to any terms associated with the receiving organization.

How We Use Your Personal Information

We will not use or disclose your Personal Information in a manner inconsistent with applicable law or this Privacy Promise. Examples of our uses and disclosures include:

• We may use your e-mail address to respond to messages sent by you and to send information that may be of interest to you.
• We may use Your Personal Information for our own internal purposes.

In certain circumstances, we may be legally compelled to release your Personal Information in response to a court order, subpoena, search warrant, or law or regulation.

How You Can Correct/Update Your Personal Information

You can correct or update your Personal Information at any time using the following options:

• Via the website: Click on the Contact/Feedback link at the bottom of a web page and send us an e-mail; and
• Send an e-mail: Response to any e-mail sent to you or otherwise follow the instructions included in an e-mail.

Transfer of Personal Information and Non-Personal Information

All Personal Information and Non-Personal Information obtained through our Site is owned by us. Accordingly, if we are acquired, merge with another entity, or divest one or more of our businesses, affiliates or subsidiary companies, the Sites, and any Personal Information and Non-Personal Information obtained through them, may be transferred to an applicable entity for the purpose of continuing to provide information regarding our Specialty Benefit Services, in accordance with applicable law.

Linking Policy

Our Site may contain hyperlinks allowing our users to connect to websites owned by our third-party vendors, distributors, and providers (“Linked Sites”). You may also access our Site through a hyperlink embedded in a Linked Site. We provide hyperlinks to the Linked Sites to enable you to conveniently access websites that may be of interest to you. Please note that once you click on a hyperlink that transfers you from our Site to a third-party’s Linked Site, you have left our Site, and this Privacy Promise will immediately cease to apply to any subsequent activity on the Linked Site. We are under no obligation to notify you when you have left our Site and have accessed a Linked Site. Use of any Linked Site will be governed by the privacy policy (if any) on the Linked Site. You may, at your option, participate in surveys though an affiliate that controls a Linked Site. Certain Non-Personal Information that you choose to provide through a Linked Site (such as comments) that is subsequently provided to us by the Linked Site provider in connection with a service engagement may be identifiable to us as your Personal Information. We will not share any information that we identify as Personal Information with the Linked Site provider.

Patient Portal

The “Patient Website” is a patient-only account portal available that, when available through the Site (e.g., via a widget), enables registered users to access their personal account information and to use certain other services offered only to registered patients who use the Patient Website. The Patient Website is subject to different terms of use and privacy promise agreements than the agreements applicable to this Site.

Security Statement

We are committed to protecting the privacy and security of this website across the entire transaction process. We take reasonable technical and procedural precautions to protect the information provided by our members. Our Internet infrastructure is protected using industry recognized commercial security products, including current encryption technology, and best practice procedures for maintenance of the website. In addition, our infrastructure is monitored 24 hours a day, seven days a week.

No method of transmission over the Internet or storage of data on an Internet server is 100% secure. Although we use commercially acceptable and reasonable precautions to protect your Personal Information, we do not guarantee its absolute security.

Your Acceptance of this Privacy Promise

You are deemed to have assented to the terms and conditions contained in this Privacy Promise when you use the Site. You are deemed to have accepted this Privacy Promise each time you access the Site. If you do not agree to the terms of this Privacy Promise, please do not use the Site. The terms and conditions contained in this Privacy Promise are subject to and may be superseded by applicable Federal and State laws.

Changes in Our Privacy Promise


We use Non-Personal Information and Personal Information only within the scope of use described in this Privacy Promise. However, we reserve the right, from time to time in our sole and absolute discretion, to change, to modify, or to add terms or remove terms from this Privacy Promise without advance notice to you. Changes to this Privacy Promise will be reflected when we post a new version number and updated revision date. Therefore, we recommend that you check the version number and revision date prior to using the Site. Your continued use of the Site after this Privacy Promise has been updated, as shown in the version number and revision date, indicates your agreement and acceptance of this Privacy Promise, including all changes made as of the date of your use of the Site.

How to Send Us Your Comments


We welcome your comments. If you have general feedback regarding this Privacy Promise, please e-mail us. Upon submission, any suggestions you make regarding the Site become our property, and we shall have the right to use any of your comments or suggestions without further permission from or notice to you.

Specific questions regarding the enforcement of this policy should be directed to privacy@express-scripts.com.

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