Privacy Policy

Cary Rx Incorporated Privacy Policy
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‍Last modified: July 5, 2023
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‍Introduction
‍Cary Rx Incorporated (“Company” or “We” or “Our”) respect your privacy and are committed to protecting it through our compliance with this policy.
Company develops, operates and distributes certain software applications, which include web applications, hosted applications and applications for mobile devices. The applications, together with the services for communications, coordination and management by patients and healthcare professionals regarding medical conditions, and the data collection, storage, analysis and reporting tools, functions and services, that are provided via the applications, are collectively referred to as the Service.
This policy describes the types of information we may collect from you or that you may provide when you visit the website https://www.caryrx.com, https://galenai.co, use our mobile application, use our online application, use our application programming interface (“API”), use our Software-as-a-Service Product (“SaaS”), use our AI Features or enter information on the website of one of Providers that utilize our SaaS to collect information (collectively referred to as “Service” or “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
Capitalized terms used herein without definition will have the same meanings as defined in the Terms of Service and any applicable Master Services Agreement, API License Agreement, or Software-as-a-Service Agreement (“Sales Agreements”)  applicable to the Service.

This policy applies to information we collect:
●      On this Service.
●      In email, text, and other electronic messages between you and this Service.
●      Through mobile and desktop applications you access or download from this Service, which provide dedicated non-browser-based interaction between you and this Service.
●      When you interact with our advertising and applications on third-party Services and services, if those applications or advertising include links to this policy.
●      When you use our Software-as-a-Service (“SaaS”),Application Programming Interface (“API”) services, and AI Features.
●      When you enter information on one of the Providers website through their use of our Service.
●      When you enter information into any of our applications.
●      When you use our Services through our third-party vendors.

It does not apply to information collected by:
●      Us offline or through any other means; or
●      Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Service.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Service. By accessing or using this Service, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Service after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
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‍Children Under the Age of 13
‍Our Service is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Service. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Service or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at:
1300 7th St NW, Suite 200
Washington, DC 20001
support@CaryRX.com
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information.
Please see Your California Privacy Rights for more information.
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‍Information We Collect About You and How We Collect It
‍We collect several types of information from and about users of our Service, including information:
●      Collected during the Account Registration process through our Service or through our Providers;
●      By which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number, or any other identifier by which you may be contacted online or offline (“personal information“);
●      Protected Health Information (“PHI”) as defined by the Health Insurance Portability and Accountability Act (definition available here: https://www.hhs.gov/answers/hipaa/what-is-phi/index.html );
●      Data from Apple Health (https://www.apple.com/legal/privacy/data/en/health-app/ ) and Google Health (https://policies.google.com/terms) as applicable in accordance with their terms and conditions after receiving your active consent;
●      That is about you but individually does not identify you; and/or
●      About your internet connection, the equipment you use to access our Service, and usage details.
●      Entered into our AI Features, such as chat and prompt logs, output logs, Content, and anonymized usage data.
We collect this information:
●      Directly from you when you provide it to us.
●      Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
●      From third parties, for example, our business partners.
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‍Information You Provide to Us.
The information we collect on or through our Service may include:
●      Information that you provide by filling in forms on our Service, entering information into our AI Features, on our Customers website using our API, or on our Provider Websites. This includes information provided at the time of registering to use our Service, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Service.
●      Records and copies of your correspondence (including email addresses), if you contact us.
●      Your responses to surveys that we might ask you to complete for research purposes.
●      Details of transactions you carry out through our Service and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Service.
●      Specific information about you and your use of our Service (such as, for example, demographic data, profile data and frequency or duration of use).
●      Information you provide to our Provider’s through their use of our SaaS.
●      Your search queries on the Service.
You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Service, or transmitted to other users of the Service or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Service with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
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‍Information We Collect Through Automatic Data Collection Technologies.
As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

●      Details of your visits to our Service, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Service.
●      Claims feed information for prescriptions provided to us by Providers.
●      Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Contact us for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically may include personal information, or protected health information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Service and to deliver a better and more personalized service, including by enabling us to:
●      Estimate our audience size and usage patterns.
●      Store information about your preferences, allowing us to customize our Service according to your individual interests.
●      Speed up your searches.
●      Recognize you when you return to our Service.
The technologies we use for this automatic data collection may include:
●      Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Service. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Service.
●      Web Beacons. Pages of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Service statistics (for example, recording the popularity of certain Service content and verifying system and server integrity).
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‍Third-Party Use of Cookies and Other Tracking Technologies
‍Some content or applications, including advertisements, on the Service are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Service. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
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‍How We Use Your Information
‍We use information that we collect about you or that you provide to us, including any personal information:
●      Except as set forth below, at no time will any of your Personal Data or Personal Information be shared with any third party by Company. Your IP address is not linked to personally identifiable information, but is used to gather broad demographic data and to monitor statistics to improve the Service. Company uses Traffic Data to help diagnose problems with its web servers, to administer the Service and to analyze user trends and behaviors.
●      Company will share Traffic Data with certain third parties for the purposes of technical and customer support.
●      Company collects, stores, processes and analyzes Service Data and produces Analytics. The term Analytics means user profiles and statistics, metrics, abstractions and other analyses that are based on or derived from your use of the Service and Service Data, which are developed in the aggregate with other data, results and measurements or in a manner that does not disclose the identity of any Provider or any specific Service Data (except in aggregated or de- identified form).
Company will use your Service Data and exploit Analytics in the manner and for the purposes described in the Terms of Service and applicable sales agreement, including without limitation:
●      to use Service Data to communicate with you and Providers (as the case may be);
●      to include, copy, disclose, distribute, transmit and display Service Data in communications with Provider (and vice versa) that have been properly initiated via the Service;
●      to access, record, collect, copy, store, process, analyze and use Service Data to provide the Service (including with regard to the use of PHI in messaging with Provider;
●      to develop, improve, extend and test the Service (and underlying technology platforms); to design, develop and produce Analytics;
●      to market and promote Company and the Service using Analytics; and to disclose, distribute and transmit Service Data and/or Analytics to Providers.To present our Service and its contents to you.
●      To improve our Services and conduct research.
●      For AI Features, to improve on LLM’s that we utilize.
●      To provide you with information, products, or services that you request from us.
●      To provide Services to our Providers who use our SaaS.
●      To fulfill any other purpose for which you provide it.
●      To provide you with notices about your account, including expiration and renewal notices.
●      To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
●      To notify you about changes to our Service or any products or services we offer or provide though it.
●      To allow you to participate in interactive features on our Service.
●      In any other way we may describe when you provide the information.
●      For any other purpose with your consent.
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‍Disclosure of Your Information
‍We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
●      To our subsidiaries and affiliates.
●      To our Providers and customers.
●      To our third-party Vendors as necessary.
●      To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
●      To a third-party LLM vendor (such as OpenAI) for our AI Features,
●      To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CaryRX Incorporated’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by CaryRX Incorporated about our Service users is among the assets transferred.
●      To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
●      To fulfill the purpose for which you provide it.
●      For any other purpose disclosed by us when you provide the information.
●      With your consent.
We may also disclose your Personal Data orPersonal Information:
●      With our third-party vendors who we have contracted with to provide Services to you.
●      With our third-party vendors who may conduct research and follow ups for us.
●      With our Providers and Customers as necessary to deliver Services.
●      To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
●      To enforce or apply our Terms of Service or applicable sales agreement and other agreements, including for billing and collection purposes.
●      If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Cary RX Incorporated, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
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‍Choices About How We Use and Disclose Your Information
‍We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
●      Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.
●      Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties’ products or services, you can opt out by sending us an email stating your request to support@CaryRX.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience, or other transactions.
We do not share any personal information with third party advertisers, advertising agencies, or marketing agencies.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights below for more information.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: support@CaryRX.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
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‍AI Features
‍Our third party LLM providers may receive details about your interactions with our AI Features (including the contents of your chats, upvotes, etc.) to provide and generally improve their services, which they may process in their legitimate business interests. Your Services user account information (e.g., username and email) is not shared with any third party LLMs or developers. Third party developers that create AI Features using APIs may view and store your chats on their servers in order to train their models.
Keep in mind, any information you provide to the AI Features will be shared with third party LLM providers and developers powering the bots, and there is no need to share sensitive personal information with the bots (e.g., credit card information, social security information, etc.).
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‍Health Insurance Portability and Accountability Act of 1996 (HIPAA)
‍In operating the Service, and as it relates to PHI, Company endeavors to comply in all material respects with Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Pursuant to HIPAA, medical facilities or professionals from whom Company receives information about patients may be Covered Entities (as defined under HIPAA), and we may serve as their Business Associate (as defined under HIPAA). As a result, some of the information we collect may constitute PHI (as defined in HIPAA).
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‍Telecom Consumer Protection Act (TCPA) Consent and Privacy
‍In operating the Service, and as it relates to communication company and our providers make with you through means governed by the Telecom Consumer Protection Act (“TCPA)”, Company endeavors to comply in all material respects with the TCPA. Pursuant to TCPA,
Notwithstanding any current or prior election to opt in or opt out of receiving telemarketing calls or SMS messages (including text messages) from us, our agents, representatives, affiliates, service providers, third-party vendors, or anyone calling on our behalf (“Us”), you expressly consent to be contacted by Us for any and all purposes arising out of or relating to the Service at a telephone number or physical address you provide.
You agree we may contact you in any way, including SMS messages (including text messages), calls using prerecorded messages or artificial voice, and calls and messages delivered using auto telephone dialing system or an automatic texting system. Automated messages may be played when the telephone is answered, whether by you or someone else. In the event that an agent or representative calls, he or she may also leave a message on your answering machine, voice mail, or send one via text message.
You consent to receive SMS messages (including text messages), calls and messages (including prerecorded and artificial voice and autodialed) from Us at the specific number(s) you have provided to Us with information or questions related to your use of the Services, specifically for research, customer survey, patient safety calls, order fulfillment inquiries. You represent that you are permitted to receive calls at the telephone numbers you have provided to Us. You agree to promptly alert us whenever ou stop using a particular telephone number. Your cellular or mobile telephone provider will charge you according to the type of plan you carry. You also agree that we may contact you by email, using the email address you have provided to us or may provide to us in the future. We may listen to and/or record phone calls between you and Us without notice to you as permitted by appliable law. For example, we may listen to and record calls for quality and monitoring purposes.
You may revoke your consent and opt out of communications by contacting us at: privacy@caryrx.com
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‍Do Not Track Policy
‍Currently, Company  will not share Personal Data with any third party for purposes that are not related to the Service or its arrangements with applicable Providers. Company may, however, disclose Personal Data if (a) reasonably necessary for Company (or its service providers) to operate the Service, including processing your queries, responses and other messages, (b) to communicate with Patients, Clinicians and Providers, (c) otherwise permitted under the Privacy Policy or elsewhere in the Terms of Service and Terms of Sale, (d) Company reasonably believes that such action is necessary to conform or comply with any legal, regulatory, law enforcement or similar requirement or investigation, to protect or defend the rights or property of Company or any third party or to enforce the Terms of Service and Terms of Sale or (e) otherwise authorized by you.
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‍Third-Party Connections
‍You may be able to access the Service and/or communicate with the Service from, and you may be able to link or communicate from the Service to, applications, devices, distribution platforms and websites owned and operated by Providers. These other applications, devices, platforms and websites are not operated or controlled by Company. Additional or different terms and conditions (including without limitation, privacy and security practices) apply when you access and use such other applications, devices, platforms and websites, which are not the responsibility of Company.
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‍Accessing and Correcting Your Information
‍You can review and change your personal information by updating your profile in our mobile application or by sending us an email at care@CaryRX.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the Service, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Service users. Proper access and use of information provided on the Service, including User Contributions, is governed by our Terms of Service.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
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‍Data Security
‍We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Service. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Service.
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‍Your California Privacy Rights
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Privacy Rights Under the California Consumer Privacy Act (“CCPA”)
‍If you’re a California resident, California law requires us to provide you with some additional information about how we collect, use, and share your “personal information” as defined in the CCPA. If there are any conflicts between this section and any other provision of this Privacy Policy and you’re a California resident, the portion that is more protective of your personal information shall control to the extent of such conflict.
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‍Summary of Personal Information We Collect. Throughout this Privacy Policy, we describe the personal information we collect, the sources of that information, and how we use and share it. Under the CCPA, we also have to provide you with the “categories” of personal information we collect and disclose for “business purposes” (as those terms are defined by applicable law). Those categories are identifiers (such as name and email address); commercial information (such as transaction history); financial data (such as financial account information); internet or other network or device activity (such as IP address or usage data); geolocation information (such as general location); health data; inference data about you; legally protected classifications (such as gender); sensory data; (such as voice recordings made during calls with our customer support team); or other information that identifies or can be reasonably associated with you.
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‍Use and Sharing of Personal Information. We use these categories of personal information consistent with the various business and commercial purposes we describe in this Privacy Policy. Check out “How do we use your information?” above to learn more. We may share this information with third parties as described above in “Why and how do we share your information we collect with third parties?”.
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‍Your Privacy Rights. You have the following rights under the CCPA with respect to your personal information.
●      Right to Know. You’ve the right to request details of the personal information about you that we’ve collected and used subject to our receipt and confirmation of your verifiable consumer request. Specifically, we’ll disclose to you:
●      The categories of personal information we collected about you;
●      The categories of sources for personal information we collected about you;
●      Our business or commercial purpose for collecting your personal information;
●      The categories of third parties with whom we shared your personal information;
●      The specific pieces of your personal information; and
●      If we disclosed your personal information for a business purpose over the past 12 months, a list identifying the personal information categories that each category of recipient obtained.
●      Right to Delete. You’ve the right to request the deletion of your personal information that is collected or maintained by us subject to our receipt and confirmation of your verifiable consumer request. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your information to provide you with the Services or complete a transaction or other action you’ve requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
●      Right to Opt Out of Sale. CaryRX doesn’t sell personal information and will not sell personal information without providing a future right to opt-out of such a sale.
●      Right to Non-Discrimination. We may not discriminate against you because you’ve exercised any of the privacy rights described above.
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‍Exercising Your Rights. To exercise the rights described above, you (or your authorized agent) must send us a request that (1) provides sufficient information to allow us to verify that you’re the person about whom we’ve collected personal information, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Satisfaction of both criteria means your request is a “verifiable consumer request” and we’re not required to respond to requests that don’t meet these criteria. We’ll only use personal information provided in a request to verify your identity and complete your request. You don’t need an account to submit a request.
We’ll work to respond to your request within 45 days of receipt. We’ll not charge you a fee for making a request unless your request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your request warrants a fee, we’ll notify you of the fee and explain that decision before completing your request.
You may submit a request using the following methods:
●      Email us at support@caryrx.com
●      In writing 1300 7th St NW, Suite 200, Washington, DC 20001.
You may authorize an agent to exercise your rights on your behalf. To do this, you must provide your authorized agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your authorized agent when they make a request on your behalf. If we’ve collected information on your minor child, you may exercise the above rights on behalf of your minor child.
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‍Non-US Users
‍YOU EXPRESSLY CONSENT TO THE TRANSMISSION, COLLECTION, STORAGE, PROCESSING AND USE OF THE ANALYTICS AND YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. YOUR PERSONAL DATA MAY BE COLLECTED, STORED, PROCESSED, USED AND TRANSMITTED WITHIN, FROM AND TO THE COUNTRY WHERE IT WAS COLLECTED AND THE UNITED STATES. UNITED STATES LAWS REGARDING THE USE OF PERSONAL DATA MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY
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‍Changes to Our Privacy Policy
‍It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Service home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Service home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Service and this privacy policy to check for any changes.
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‍Termination
‍If you terminate your registration and account for the Service, or if your registration or account is terminated for any reason by Company, then Company will remove your Service Data from the Service; provided, Company may retain and use your Service Data in the manner described herein, but only in aggregated or de-identified form.
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‍Contact Information
‍To ask questions or comment about this privacy policy and our privacy practices, contact us at:
1300 7th St NW, Suite 200
Washington, DC 20001
support@caryrx.com
To register a complaint or concern, please email support@caryrx.com