Afaxys Group Services Privacy Notice

Afaxys Group Services, LLC (“AGS” or “We”) values privacy. In this Privacy Notice (“Notice”), we describe how we collect, use, and disclose information that we obtain about users of our Services which are available through the AGS Platform (collectively, the “Services”), and how we use and disclose that information. The AGS Platform is a business-to-business private portal which can only be used by registered participants (“Participants”). Separate privacy policies are available to users of our other websites, Afaxys; Afaxys Pharma; and Afaxys Marketplace.

What Information Do We Collect and Why?

We may collect information about Participants and their authorized users directly from authorized users and from third parties, as well as automatically through the use of our Services through the AGS Platform. The information we collect can be summarized as follows:

How We Share Your Information

We may share your information, including personal information, as follows:

• Suppliers. Your user name and any information that you post to the AGS Platform will be available to, and searchable by, users of the AGS Platform and Services.
• Members. We provide buyers and suppliers with information that is reasonably necessary for buyers to communicate with suppliers regarding the purchase and shipment of products purchased from supplier and any issues that may arise in connection with their purchase.
• Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your information will be subject to this Notice.
• Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf, such as information management vendors, our webhosting company, and legal or accounting advisors.
• Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
• In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
• To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Notice, or as evidence in litigation in which AGS is involved.
• Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or other commercial purposes. We do not sell identifiable personal information about our customers to third parties for their own independent use.

Our Use of Cookies and Other Tracking Mechanisms

We and our third party service providers use cookies and other tracking mechanisms to track information about your use of AGS services and products. We, and our third-party service providers, may combine this information with other information we collect from you. Our systems may not recognize or comply with browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section.

Cookies

Cookies are alphanumeric identifiers that we place on your computer’s hard drive through your web browser for record-keeping purposes. Some cookies make it easier for you to navigate our websites, while others enable a faster log-in process or track your activities on our websites. There are two types of cookies: session and persistent cookies.

• Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session. This allows us to process your online transactions and requests and verify your identity, after you have logged in as applicable.
• Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We may use persistent cookies to track aggregate and statistical information about user activity, and to display advertising both on our websites and on third-party sites.

Disabling Cookies

Most web browsers automatically accept cookies. If you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to the Platform who disable cookies will be able to browse certain areas of the Platform, but some features may not function.

Our Use of Cookies and Other Tracking Mechanisms

We and our third party service providers use cookies and other tracking mechanisms to track information about your use of the Marketplace Platform or Services. We may combine this information with other information we collect from you (and our third party service providers may do so on our behalf). Our systems may not recognize or comply with browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section.

Clear GIFs, Pixel Tags and Other Technologies

Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our websites to, among other things, track the activities of visitors, help us manage content, and compile statistics about website usage. We and our third-party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third Party Analytics

We may use automated devices and applications, such as Google Analytics, to evaluate usage of tour websites and evaluate our services. These tools can help us improve our services and products, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties.

Do Not Track Disclosure

We may track your activities once you leave our websites. While there is still no universally accepted standard regarding tracking, our websites do respond to certain Do Not Track signals (e.g. the Mozilla Firefox Do Not Track feature), but in some cases it may not be able to restrict tracking. You may also disable certain tracking as discussed above (e.g., by disabling cookies). For more information about tracking, please click here.

User Generated Content

If you post content to our websites, all of the information that you post may be available to other visitors or users of the websites.

Third-Party Links

Our websites may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Notice, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

Security of My Personal Information

We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

What Choices Do I Have Regarding Use of My Personal Information?

We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Services you have requested or received from us.

Children Under 13

Our Services are not designed for children under 13 and we do not knowingly collect data from children under 13. If you discover that a child under 13 has provided us with personal information, please inform us at the contact information below and we will delete it from our systems.

Special Information for California Residents

California residents have a number of data rights authorized by the California Consumer Privacy Act (“CCPA”). These rights are:

• The right to receive information about the categories of personal information we have collected about you, the categories of sources we have received it from, the business or commercial purpose for collecting or selling it, the categories of third parties with whom we have shared personal information, and the specific pieces of information we have collected about you.
• The right to obligate us to delete the personal information we have collected about you excluding that collected in a limited set of circumstances, such as research studies and the minimum necessary for legal compliance.
• The right to obligate us to correct errors in the personal information we have about you.
• The right to opt-out of the sale of your personal information. Since we do not sell your personal information, this right is moot.

You may make two requests per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may exercise any of these rights contacting us in writing at: notices@afaxys.com. Please note that we will require you to verify your identity by providing us with supporting information before fulfilling your request. Please allow up to forty-five (45) days for the completion of your request.

We will not discriminate against you for exercising these data rights. To the greatest extent possible, we will provide you with the same quality of service at the same price after exercising these rights. Please note that we may not be able to offer you services that depend upon having a history of your transactions with us, or similar personal information, if you exercise your right to delete your personal information.

Contact Us

If you have questions about this Notice or other privacy matters, or would like to make a complaint, please contact us at notices@afaxys.com or at: Attn: Legal Department, PO Box 20605, Charleston, SC 29413.

Changes to this Notice

This Notice is current as of the Effective Date set forth above. We may change this Notice from time to time, so please be sure to check back periodically. If we make any changes to this Notice that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our website.