Consumer Health Data Privacy Policy

Date last modified: June 2024

This policy serves as an addendum to the EuroPharma, Inc., home of the Terry Naturally brand (hereinafter, ‘EuroPharma”, “we”, “our”, “us”), Privacy Policy. This Consumer Health Data Privacy Policy applies to identifiable personal health information that could be linked or reasonably linked to a consumer and that identifies a consumer’s past, present, or future physical or mental health status.

BY USING OUR SITES, INTERACTING WITH OUR SOCIAL MEDIA PLATFORMS, SUBSCRIBING TO OUR NEWSLETTERS, PARTICIPATING IN OUR PROMOTIONS, PLACING ORDERS, OR COMMUNICATING WITH US OVER THE PHONE OR ELECTRONICALLY, YOU CONFIRM YOU HAVE READ AND CONSENT TO OUR PRIVACY POLICY, OUR TERMS & CONDITIONS, AND THIS CONSUMER HEALTH DATA PRIVACY POLICY. IF YOU DO NOT CONSENT TO OUR PRIVACY POLICY, TERMS & CONDITIONS, AND THIS CONSUMER HEALTH DATA PRIVACY POLICY YOU SHOULD NOT USE EUROPHARMA, INC’S SERVICES, AND YOU SHOULD LEAVE THE SITE IMMEDIATELY AND NOT PROVIDE EUROPHARMA WITH ANY PERSONAL INFORMATION.

We will modify the Privacy Policy, Terms & Conditions, and this Consumer Health Data Privacy Policy from time to time. The updated Policy will always be posted on our site and will indicate when the Policy was last revised. You should periodically review our current Policies to stay informed of personal data practices within our organization.

Your continued business relationship with us or use of any of our sites and services after the changes are posted constitutes your acceptance of any changes, both with regard to the information we have previously collected from you and information we may collect from you in the future. Your privacy is important to us. At EuroPharma, Inc. we are committed to maintaining the privacy of your personal information and to protecting such information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

EuroPharma, Inc does NOT sell any consumer health data. EuroPharma only shares health data as required by the FDA in terms of a product recall or adverse event reporting.

Consumer Health Data Collected

The data we collect depends on the context of your interactions with EuroPharma and the choices you make and the products and/or services you use. Regulation defines consumer health data very broadly, as a result many of the categories of data we may collect could be considered consumer health data.

Examples of consumer health data may include:

  • Information about your health-related conditions, symptoms, status, diagnoses, treatments, or test results. We may collect these pieces of information from you ONLY if you provide us with such detail. For example, if you are asking us a health-related question, about a specific product, looking for a product recommendation, or reporting an adverse event.
  • Measurements of your bodily functions, vital signs, or characteristics, including photographs, which may also be considered biometric information under MHMDA. We may collect these pieces of information from you ONLY if you provide us with such detail. For example, if you are asking us a health-related question, about a specific product, looking for a product recommendation, or reporting an adverse event.
  • Information about your social, psychological, behavioral, and/or medical interventions; health-related surgeries or procedures; use of prescribed medications; and genetic data. We may collect these pieces of information from you ONLY if you provide us with such detail. For example, if you are asking us a health-related question, about a specific product, looking for a product recommendation, or reporting an adverse event.
  • Location information that could reasonably indicate an attempt to acquire or receive health services or supplies, however this information is not identifiable.
  • Information that identifies the product searches you may have performed or products you may have purchased that could be interpreted by MHMDA as consumer health data. This information may be used and shared to perform cross-contextual advertising.

For full details please review the following chart.

Personal Information
Category Descriptive Examples Is Information Shared? Business Purpose for Collecting and/or Sharing
Online Identifiers IP address, device information, cookies, pixel tags and similar technologies. No General non-identifiable analytical data.
Commercial Information Products you purchased. Yes For our business records. In the event there is a product recall, information could be shared with the FDA.
Health Data You may furnish us with health-related information in asking a question or reporting an adverse reaction to the use of a product. Yes To provide a response to a question. In the event of an adverse event, detail may be provided to the FDA to fulfill reporting requirements.
Internet and Electronic Network Data Browsing history, search history, interaction with an internet website or ad, pages visited, time spent on pages. No General non-identifiable analytical data.
Your Feedback Information you provide about our Services, which may include surveys and/or product reviews and testimonials. No To better our Services and provide feedback regarding product reviews, and post testimonials on our websites, use in marketing materials, and post on social media.
Geolocation Data Information about general city, state, or region in which a user is located. No General non-identifiable analytical data.
Inferences Inferences drawn from some of the personal information categories listed herein and used to create a general consumer profile reflecting your purchasing and marketing preferences, characteristics, and behaviors. Yes General non-identifiable analytical data.

 

We may also collect information that YOU publicly post on our social media pages such as our Facebook®, Instagram®, YouTube® pages, etc. Information is collected only if you are requesting we provide you with a response. The information collected is used so that we may respond to you and is not used for any other purpose.


Sources of Consumer Health Data

We collect consumer health data directly from you, from your interactions with our products and services, along with interactions within our accounts on social media platforms.

When you visit this site, EuroPharma records certain information that your Web browser sends whenever you visit any Web site.

EuroPharma collects information that you provide when placing an order, providing reviews/testimonials, interacting with our social media platforms (e.g., Facebook, Instagram, etc), communicating with us over the phone, email or otherwise, or other requests for information. Like most Web sites, we use cookies to gather general visitor information and track visits to our Web site.

Why We Collect and Use Consumer Health Data

EuroPharma may collect and use consumer health data for the purposes of responding to questions you may have asked us, to fulfil your product order(s), and for reporting purposes as required by the Food and Drug Administration with respect to adverse events and product recalls.

Sharing of Consumer Health Data & Third Parties

EuroPharma does not sell any consumer health data.

We may share health data to complete transactions and to provide you with the services or products you’ve requested.

EuroPharma may share your personal health information in other circumstances as required by law or if we believe sharing the personal health information will help protect the safety, property, and rights of our customers, associates, and other persons.

Some applications on this Web site are served by third parties, including content providers and application providers. Visitors should consult the other Web sites’ privacy policies as EuroPharma, Inc. has no control over information that is submitted to, or collected by, these third parties. Each third-party Web site is solely responsible for its own privacy practices and policies.

How to Exercise Your Rights

EuroPharma does not sell any consumer health data.

The following are your privacy rights as outlined by regulation:

Right to Confirm—You have the right to confirm whether EuroPharma is collecting, sharing, or selling consumer health data. EuroPharma confirms that collection and sharing of consumer health data is per the section titled ‘Consumer Health Data Collected’.

Right to Access—You have the right to request a copy of the consumer health data we have collected and shared. To exercise this right, please click here. Complete the form in full and be sure to select “Consumer Health Data Request”.

Do Not Share—You have the right to request your health data not be shared. EuroPharma does share your health data for the purpose of cross-contextual advertising. If you would like to exercise this right, please click here. Complete the form in full and be sure to select “Do Not Share Personal Information”.

Right to Delete—You have the right to request deletion of the consumer health data we have collected. Please note that EuroPharma will send notice to our service providers to delete your health data. EuroPharma however will not be able to delete your information from our records as we must maintain records in order to comply with the FDA’s requirements surrounding product recalls and adverse events. If you would like to exercise this right, please click here. Complete the form in full and be sure to select “Deletion of Personal Information”.

Right to Withdraw Consent—You have the right to withdraw consent to the collection and sharing of your health data. If you wish to withdraw consent to the collection of your health data, you should not place any orders, use our websites or social media sites, or contact us with any health or product questions. If you wish to withdraw consent of the sharing of your health data, please click here. Complete the form in full, making sure to select ‘Do Not Share Personal Information’.

Authentication

All requests will be authenticated before they are processed. Authentication will consist of comparing the data YOU submitted on the privacy request form to the data in our technologies to ensure the request is being made by the actual consumer. If EuroPharma is unable to authenticate a request, after three attempts, the request will not be carried out and the consumer will be notified accordingly.

Appeal Process

If authentication is unsuccessful and you wish to appeal, please click here. Complete the form in full and be sure to select ‘Appeal Request’. EuroPharma will make three attempts to authenticate the request. If the appeal cannot be processed, EuroPharma will provide an explanation of action taken or not taken in response to the consumer appeal.

Washington residents: If the appeal is denied and you reside in the State of Washington, you may contact the Washington attorney general to submit a complaint using the following link: atg.wa.gov/file-complaint.

Nevada residents: If the appeal is denied and you reside in the State of Nevada, you may contact the Office of the Attorney General to submit a compliant using the following link: 2019-06-04_Complaint_Form.pdf.

How Is Your Consumer Health Data Protected?

EuroPharma, Inc. takes reasonable steps to protect consumer health data. EuroPharma, Inc. uses technologies and processes such as access control procedures, network firewalls, and physical security. These technologies and methods increase the security and privacy of information traveling to, from, and within the EuroPharma, Inc. network.

EuroPharma, Inc. also safeguards consumer health data from unauthorized access. Only authorized EuroPharma, Inc. employees, service provides, or agents carrying out permitted business functions are authorized to access consumer health data.

Although we have excellent security measures in place, no data transmission over the Internet is one hundred percent secure. As a result, we cannot guarantee the security of any information you submit to our site. Additionally, we are not responsible for the security of personal information you transmit to the site and/or the services over networks that we do not control, including the internet and wireless networks. You agree that you provide us with any consumer health data at your own risk. We shall not be liable or responsible for any data incident or event that may compromise the confidentiality, integrity, or security of your consumer health data caused by a third party.

The safety and security of your consumer health data also depends on you. You are responsible for maintaining the security and confidentiality of your username and password if you have an account. This information should not be shared. If you have reason to believe that your username and password have been compromised, you must contact us immediately. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your consumer health data.

Changes to EuroPharma, Inc.’s Consumer Health Data Privacy Policy

EuroPharma, Inc. may make changes to this policy from time to time. We will post changes to our consumer health data privacy statement here, so be sure to check back periodically. Your continued use of EuroPharma, Inc. sites and/or interactions with EuroPharma, Inc. constitutes your agreement to this Consumer Health Data Privacy Policy and any future revisions.

Persons with Disabilities

EuroPharma strives to ensure that every person has access to information related to our site, including this Consumer Health Data Privacy Policy. Please contact us if you would like this Policy provided in an alternate format and we will do our best to meet your needs.

Questions Regarding This Consumer Health Data Privacy Policy

If you have any questions pertaining to our Consumer Health Data Privacy Policy, please feel free to contact us by clicking here or calling 877-575-5155. If you would like to submit a consumer health data privacy request, please refer to the section “How to Exercise Your Rights?”.