Privacy Policy

This Privacy Policy describes how PBM Accountability Project (“PBMA”) collects, uses, and discloses information with respect to your use of the website located at https://www.pbmaccountability.org/, as well as other websites owned and/or operated by PBMA that link to this Privacy Policy (collectively, the “Website”).

Before you use or submit any information in connection with the Website, carefully review this Privacy Policy. By using the Website, you agree to the collection, use, and disclosure of your information as outlined below. The terms “you” or “user” refer to all individuals and entities accessing the Website for any reason. The terms “us” or “we” refer to PBMA.

Collection of Personal Information

The information we collect from you and about you depends on how you use the Website and the information you provide to PBMA. We collect information in three main ways: (1) information you choose to provide to us; (2) information we collect automatically through technology when you use the Website; and (3) information we collect from others.

Information You Provide To Us

We collect information about our users when users choose to provide that information to us, for example, we collect information when you send us a message through the Website. The kinds of information we collect may include your name, your email address, and your phone number, as well as any other information you provide to us in connection with your use of the Website. Sometimes you may provide the information to a trusted third party on our behalf instead of directly to us. In such circumstances, the third party’s privacy policy and terms apply as to how it collects and processes the information you provide.

Information that Is Passively and Automatically Collected

When you visit the Website, we may automatically receive and record information from your computer or mobile device. This information allows us to understand how people are navigating and using our Website and how we can improve your experience based on the information we collect. The types of information we may collect include, by way of example only, your IP address, browser type, browser language, operating system, state or country from which you accessed the Website, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, files you download, pages viewed, the amount of time spent on particular pages, the date and time you used the Website, error logs and other similar information. From your IP address, we may be able to infer your general location (e.g., city and state or postal code).

We may use third-party analytics providers and technologies, such as cookies, web beacons, tracking pixels, or gifs, to help us collect the data described above. We use the term “cookie” in the broad sense to include all similar techniques and technologies. A cookie is a small text file that is placed on your computer or device when you visit a website that stores certain information about your website usage. For example, cookies enable us to recognize your computer; store your preferences and settings; enhance your user experience by delivering content specific to your interests; perform searches and analytics; and assist with security administrative functions.

You can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. If you disable cookies, some functionality of the Website may be impaired.

Information We Collect from Others

We may receive additional information about you from third parties and other sources, such as from public records, marketers, researchers, analysts, social media networks, data aggregators, and other organizations. We may combine this information with information we collect directly from you to derive your possible interests and to provide a more relevant experience for you and to improve the Website.

How We Use Your Information

We may use the information we collect for the following purposes:

For the purposes for which you provided the information, including:
- To respond to your messages.
To maintain and improve the Website, including:
- To provide the features and services available through the Website;
- To improve the content and features of the Website or to develop new services;
- To administer and troubleshoot the Website.
To communicate with you, including:
- To send you information about your relationship with us;
- To contact you with information that we believe may be of interest to you;
- To process and respond to your inquiries or to request your feedback.
For internal research and reporting.
For our business operations, including for security, fraud prevention, and legal compliance.
To comply with laws and regulations for our legitimate interests or the legitimate interests of others.
For other purposes for which we seek your consent in accordance with applicable legal requirements.

If you provide us with your email address, we may add you to our email distribution list. If you wish to stop receiving emails from us, please email info@pbmaccountability.org or click the unsubscribe link in the footer of an email from us. Please note that opting out or unsubscribing will not prevent you from receiving communications that are not marketing in nature, such as important notices about changes to our terms and policies.

If you provide us with your mobile number, you consent to receiving calls and messages, including autodialed and automated calls and texts, from PBMA. Message and data rates may apply. If you wish to stop receiving calls and messages from us, please text STOP in response to any text message you receive from us.

We may also aggregate or de-identify information we collect from you so that it is no longer linked to you or your computer or device, or we may collect information that is already in de-identified form. Our use and disclosure of aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may, in our sole discretion, use and disclose such information for any lawful purpose.

When We Disclose Your Information

We may disclose your information to or with third parties under the following circumstances:

With Consent. We may disclose your information with your consent.
To Service Providers. We may provide access to or disclose your information with select third parties that perform services for us to help us run our organization. These may include, for example, entities that provide data hosting and storage, help desk software and email services, security, research and analytics, and legal services.
With Collaborators and Other Select Entities. We may disclose your information (except for text messaging opt-in data and consent information or your credit card information) with other organizations with whom we may collaborate, with companies whose products, offerings, or services we believe may be of interest to you, and with select marketing companies and data co-op firms.
Protection of PBMA and Others. PBMA may disclose your information if required to do so by law or in a good faith belief that disclosure is permitted by this Privacy Policy or reasonably necessary or appropriate for any of the following reasons:
- to comply with legal process;
- to enforce this Policy, including investigation of potential violations thereof;
- to respond to your requests for customer service; and/or
- to protect the rights, property, or personal safety of the PBMA, its agents and affiliates, users, andthe public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
Organizational Transfers. If we participate in a merger, acquisition, bankruptcy, or other transfer or reorganization of assets (including in contemplation thereof, e.g., due diligence), we may disclose your information because user information collected through the Website may be among the transferred assets.
Aggregated Data. We may disclose aggregated and de-identified information.

How We Protect Your Information

We have implemented administrative, technical, and physical security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information because, despite our efforts, no Internet and/or other electronic transmissions can be completely secure.

Legal Basis for Processing Personal Data

The laws in some jurisdictions require that website operators tell you about the legal grounds they rely on to use or disclose your information. To the extent those laws apply, our legal grounds for processing your information are as follows:

Where use of your information is necessary to perform our obligations to you;
Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our Website; to provide the services we provide through our Website; to defend our legal rights; to analyze the use of our Website; to improve our services);
Where we have a reason to process the information in accordance with applicable law;
Where we have your consent to engage in a particular type of processing activity.

Online Analytics

We may use third-party web analytics services (such as those of Google Analytics) in connection with the Website to collect and analyze the information discussed above, and to engage in auditing, research, or reporting. The information (including your IP address) collected by various analytics technologies described in the “Information that Is Passively and Automatically Collected” section will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Website, including by noting the third party website from which you arrive, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. Information about how Google uses information collected from sites that use its services is located at https://policies.google.com/technologies/partner-sites. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on here: https://tools.google.com/dlpage/gaoptout.

Non-U.S. Visitors

The Website is not intended for individuals located outside of the U.S. If you are a non-U.S. resident, you acknowledge that our collection and processing of personal information is subject to United States law, and that any personal information you provide to us shall be processed in the United States, where the laws and regulations may not provide the same level of data protection rights as in the jurisdiction in which you are located.

Children’s Privacy

The Website is intended for general audiences and is not directed at children. If we become aware that we have collected information without legally valid parental consent from children under an age where such consent is required under applicable law, we will take reasonable steps to delete it as soon as possible.

Third-Party Links and Websites

The Website may contain links to third-party websites. Please be aware that we are not responsible for the content or privacy practices of such other sites. The collection, use and disclosure of your information will be subject to the privacy policies of those third-party websites, not this Privacy Policy. Therefore, we encourage our users to be aware when they leave our Website and to read the privacy policies of every site they visit that collects their information.

Revisions to Privacy Policy

We will continue to review this Privacy Policy and we may make changes to the Policy from time to time. The date at the bottom of this page indicates the last time changes were made. You should check this page periodically for updates. If we make material changes to this Policy, we will provide you with notice as required by law. Your continued use of the Website will signify that you have read, understood, and accepted the terms of the updated Privacy Policy.

If you have any questions about this Privacy Policy, you can contact us by emailing us at info@pbmaccountability.org.

Last Updated: September 13, 2023