Privacy Policy and Terms of Use for Clinic and Provider Portal

RxSteward^TM Privacy Policy

This RxSteward^TM Privacy Policy (“Privacy Policy” or “Policy”) describes our practices as it pertains to information we collect through our mobile applications, platforms, and services that we own or operate and that contain a link to this Privacy Policy (collectively, “RxSteward^TM for Patients” or “Northwind Platform”).

As used in this Policy, terms such as “we,” “us,” “our,” and “Company” refer to current and future entities affiliated with Northwind Pharmaceuticals.

By using the RxSteward^TM for Patients, you consent to our collection, use, disclosure, and storage of information as described in this Privacy Policy.

Below are the contents of this Privacy Policy:

What Information Do We Collect?
How Do We Safeguard Your Information?
How Do We Disclose Your Information?
How Can You Manage Your Information?
How Do We Use Your Information?
Rights for California Residents
Scope of this Policy
How To Contact Northwind

What Information We Collect

There may be three different methods of collecting your information: (1) information you provide directly to us; (2) information that is automatically provided to us or collected through your use of our RxSteward^TM for Patients mobile application; and (3) eligibility information we obtain from your benefit plan provider. Such Information may include your full name, telephone number, e-mail address, postal address, certain account numbers, your User ID you create or is assigned to you, and other information described in this Privacy Policy.

When you use RxSteward^TM for Patients, you may provide certain information directly to us, including when you allow us to obtain information about you from other sources.

You may limit the Information you provide or make available to us if you want to; however, that may limit your ability to access or use certain functions of the RxSteward^TM for Patients or to request certain services or information. For example, if you do not provide a prescription number for an active prescription you have received from Northwind Pharmacy, you will not be able to view your list of current medications that have been dispensed to you from your employer clinic or Northwind Pharmacy.

All data that is transmitted through our RxSteward^TM for Patients application is stored and transferred on cloud computing servers in the United States. None of your Personally Identifiable Information (PII) or your Personal Health Information (PHI) will be stored or transferred through servers outside of the United States.

How We Safeguard Your Information

We maintain administrative, technical and physical safeguards designed to protect the information that you provide on our RxSteward^TM for Patients. These safeguards vary based on the sensitivity of the information that is being collected, used and stored. However, no security system is impenetrable and we cannot guarantee the security of our RxSteward^TM for Patients, nor can we guarantee the security of the information you transmit to us over the Internet, including your use of e-mail. We are not liable for the illegal acts of third parties such as criminal hackers.

Northwind cannot fully guarantee that your personal data is 100% safe from breach, illegal acts, or third-party exploitation. However, we take every necessary precaution with your personal data and follow strict security standards well above the standards set by The United States Department of Health and Human Services.

It is your responsibility to safeguard the devices you use to access our RxSteward^TM for Patients (such as laptops, tablets and mobile devices), and to use appropriate security settings on those devices. If those devices are lost, stolen or misplaced, others may be able to access your account and your personal information using those devices. If you log into the RxSteward^TM for Patients using a public computer or device, or the computer or device of another person, you should affirmatively log out of your account (i) prior to ending your session, or (ii) if you will be inactive on the RxSteward^TM for Patients for more than a few minutes otherwise, the next user of that computer or device may be able to access your account and the Information in your account if your session has not ended.

You agree that we are not responsible for any harm that may result from someone accessing your account or personal information on a lost, stolen or misplaced device or on a public computer or kiosk where you do not for any reason take the necessary steps to log out of your account prior to ending a session on such public computer or kiosk.

Our mobile application will have the functionality to allow you to communicate securely or insecurely. Where not secure, such as regular SMS messaging, you acknowledge that voluntarily disclosing your PII/PHI does not hold Northwind or any of its subsidiaries liable for your actions. Northwind will take every effort to inform you when your messaging environment is secure for sensitive data transmission.

Our mobile application will have the functionality to send you push notifications. You have the option to disable these and all automated communication tools we employ through our mobile application.

We retain Information for as long as necessary for the purpose for which it is collected, subject to a longer period if the information is relevant to a legal challenge.

Children under 13

We will not intentionally collect any personal information (as that term is defined in the Children’s Online Privacy Protection Act) from children under the age of 13 through our RxSteward^TM for Patients without receiving parental consent. If you think that we have collected such personal information from a child under the age of 13 through our RxSteward^TM for Patients, please Contact Us immediately.

SSN Protection Policy

While we currently do not use your Social Security Number (SSN) for servicing your plan benefit, some eligibility information provided to us by your medical benefit plan administrator may include your SSN. It is our policy to safeguard your SSN and redact where possible and where necessary. If we need to obtain your SSN to appropriately serve you in the future we will update language to this policy.

Personal Health Information

You may be able to view and edit your Personal Health Information (PHI) via this application. The PHI can be collected from either your input or demographic data provided to us by your medical benefit plan provider. is You may utilize the our mobile application to export your health information for your records or to share with a healthcare provider.

PHI Data might include, but is not limited to, the following:

Name and contact information, such as address, phone number, or email address
Medical history, conditions, treatments, medications, lab results, and care team
Cohort information, enrolled programs/blueprints, and any data captured during observations
Weight, activity logs, and other health statistics collected from medical devices and smartphones
Demographic information, such as your age and gender

Northwind will only use data collected in our applications for the purposes of healthcare delivery. We may use de-identified population data for healthcare or financial decision support services.

The content provided in RxSteward^TM for Patients is not intended to be a substitute for professional medical advice, diagnosis, or treatment. Always seek the advice of your physician or other qualified health provider with any questions you may have regarding a medical condition.

How We Disclose Your Information

We will not share your personal information with any party that does not already have access to it or where there is a need to carry out your healthcare delivery in the most efficient and effective means possible. This may include your healthcare provider, wellness professionals, or pharmacy staff.

Any third-party we share your data with has undergone appropriate evaluation and scrutiny from Northwind and has entered into legal agreements that forbid further use or sharing of your PII/PHI beyond the original purpose.

We may share Information if all or part of the Company is sold, merged, dissolved, acquired, or disbanded to any extent in a similar transaction, or in connection with steps that may need to be taken in anticipation of such events.

We may share Information in response to a court order, subpoena, search warrant, or to comply with law or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting activities that are illegal, violate our rules, or may be harmful to other visitors.

Posting Messages, Comments, and Content

Our RxSteward^TM for Patients may have collaboration areas, including but not limited to “bulletin boards,” “leader boards,” and “cohort shares,” that permit users to have collaborative discussions and/or share information. Any information you submit or post to these collaboration areas, including your display name or image, may be visible by other users of the mobile application, and such users may share with others. Therefore, please be thoughtful in what you write and understand that this information may become public.

How to Manage Your Information

Our RxSteward^TM for Patients may permit you to view your profile, if applicable, and access related Information about you and to request changes to, or deletion of, such Information. You will have access to a page on the RxSteward^TM for Patients mobile app through which you may review your profile and related Information about you, and you may have options to modify, delete or obtain such Information.

Cookies and Tracking

The Company may use various technologies, including cookies, tokens, tags, web logs, web beacons, scripts, and web server logs to father automatically-collected information and may aggregate this information from our RxSteward^TM for Patients visitors or to enable certain features of our RxSteward^TM for Patients. This information may include demographic data, technical information about the technology (e.g. phone, computer) used to connect to the RxSteward^TM for Patients, web browser information, your IP address, and browsing behavior such as pages visited and how often they are visited (“Activity Information”).

How We Use Your Information

The personal information we collect on you is purely for the purposes of carrying out a service to you, your clinic providers, and your employer. We do not sell any data to 3^rd parties, especially patient data.

We only gather information for the following reasons:

Customizing your experiences, including managing and recording your preferences;
Authenticating your account information;
Effectively facilitating cohorts and chronic care programs
Developing reports regarding utilization, claims, and financials
Supporting requests for assistance with accessing your data
Outreach for user feedback and testimonials
Enabling certain functions and tools on the RxSteward^TM for Patients

As described above, we may use tracking technologies that allow us to recognize your device when you return to our RxSteward^TM for Patients within a period of time, as determined by us, and to support automatic login to your RxSteward^TM for Patients. To maintain your privacy, you should affirmatively log out of your account prior to your session ending (whether you end your session, or we end your session, for example if our RxSteward^TM for Patients has “timed out” – i.e. we have ended your session automatically after a period of inactivity as determined by us in our sole discretion). Unless you affirmatively log out of your account, you may be automatically logged back in the next time you or any user of your devices visits the RxSteward^TM for Patients.

We may use the Information for a number of purposes such as:

To respond to an e-mail or particular request from you.
To communicate with you.
To provide you with content through our RxSteward^TM for Patients or other services that we may offer.
To process an application for a product or service as requested by you.
To authenticate you on any portion of our RxSteward^TM for Patients and with vendors acting on our behalf.
To administer surveys and promotions.
To personalize your experience on our RxSteward^TM for Patients.
To provide you with informational or promotional offers, as permitted by law, that we believe may be useful to you, such as information about products or services provided by us or other businesses.
To perform analytics and to improve our products, RxSteward^TM for Patients, and advertising.
To comply with applicable laws, regulations, and legal process.
To protect someone’s health, safety, or welfare.
To protect our rights, the rights of affiliates or related third parties, or take appropriate legal action, such as to enforce our Terms of Use.
To keep a record of our transactions and communications.
As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law or for any other purpose with your consent.

We may use Information to contact you through any contact information you provide through our RxSteward^TM for Patients or any other services we offer, including any e-mail address, telephone number, cell phone number, or fax number.

We may, when permitted, combine your Information with other information, whether online or offline, maintained or available to us from you or from other sources, such as from our vendors, and we may use and disclose combined data for the purpose described in this Section or for internal business purposes. We may, when permitted, use and disclose de-identified and aggregated data for any purpose, which may include, without limitation, disclosures to third parties for analytics purposes such as evaluating the RxSteward^TM for Patients and providing additional benefits, programs, and services.

Additional Rights for California Residents

California Privacy Rights

California law permits our customers who are California residents to request certain information regarding the disclosure of personal information to third parties for their direct marketing purposes.

If we have disclosed any personal information to third parties for direct marketing purposes, we will provide a list of the categories of personal information, along with the names and addresses of these third parties to you at your request. To make such a request, write us at the postal or e-mail address found in the Contact Us section of this Policy.

This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the specified e-mail or postal address. You should put “California Privacy Rights” in the e-mail subject line and in the body of your request. You must provide us with specific information regarding yourself so that we can accurately respond to the request.

California Minors Under 18

If you are a California resident under the age of 18 and are a registered user of our RxSteward^TM for Patients, you may request that we remove from our RxSteward^TM for Patients any content you post to our RxSteward^TM for Patients that can be accessed by any other user (whether registered or not). Please note that any content that is removed from visibility on our RxSteward^TM for Patients may still remain on our servers and in our systems. To request removal of content under this provision, please write or e-mail us at the postal or e-mail address found in the please Contact Us section of this Policy. When you write us, provide us with a description of the content and the location of the content on our RxSteward^TM for Patients, and any other information we may require in order to consider your request. Please note that removal of content under this provision does not ensure complete or comprehensive removal of the content or information posted on the RxSteward^TM for Patients by you.

Scope of this Policy

This Policy applies only to the use of our mobile or software applications and websites designed and developed by Northwind. This policy does not apply to other Privacy Policies Northwind may publish as they are outside the scope of use for our web and mobile presence and platforms. This includes information that may have been collected by phone, email, fax, in person or other messaging or communication mediums.

Our Policy is not inclusive of nor covers the practices of other companies, websites, or software applications that may have integrations or linkages or may be accessed to or from any Northwind developed or branded software, website, or application.

This Privacy Policy is not a binding contractual agreement between any parties and is intended for informational purposes only.

Changes

We may change this Policy at any time. You can check back here periodically for updates or to answer any questions you may have regarding this policy.

How to Contact Us

Contact us regarding this Policy or related our privacy practices. If you believe we or any company associated with us has misused your information, please contact us immediately.

Northwind Pharmaceuticals
support@nwpharma.com | 317-522-1637 | nwpharma.com

Effective Date

January 1, 2022

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Northwind Pharmaceuticals, LLC

Terms of Use

The following terms and conditions (the “Agreement”) constitute your agreement regarding use of Northwind Pharmaceutical, LLC’s (“Northwind”) digital platform (“Platform”) and related pharmacy services (collectively, the “Services”). You represent that by agreeing to this Agreement and utilizing the Services, you are at least 18 years of age.

Permitted Uses of Platform

Use of this Platform is allowed only by strict adherence to this Agreement. The Platform may only be used for the purposes of:

Access dispensing software via Single Sign-on (SSO)
Adding/viewing patient observations from chronic care programs
Viewing patient records
Viewing and requesting changes to drug formulary
Accessing Northwind Academy’s home page
Accessing The Prescriber’s Letter
Viewing metrics and data that pertains to drug dispenses, drug spend, retail program data, and chronic care program detail
Upload documentation that is only essential to managing blueprints
View and edit User Profile
Communicate with Northwind Support personal

The Platform may not be used for any other purposes except for the Permitted Use. The Platform may only be used in compliance with all applicable laws and to access information that you are permitted to access. The Platform may not be utilized for any unlawful, illegal, obscene, threatening, harmful, abusive, or harassing purposes. You are not permitted to submit false information on the Platform. Your use of the Platform may be blocked if you violate the terms of this Agreement or do not use the Platform for the Permitted Use as permitted by this Agreement.

Disclaimer as to Medical Advice and Treatment

Provider acknowledges and agrees that the Supplier Software is an not electronic health record and information provided is not intended to be a substitute for the advice and professional judgment of a physician or other professional medical personnel. Provider will be solely responsible for the professional, medical, and technical services provided by Provider its employees and agents to Customer. Provider acknowledges and agrees that there is an existing physician/provider-patient relationship with its patients and that patients rely on Provider to determine the proper prescription for patients.

Privacy and Security

Provider shall comply with all Laws (as defined herein) as it relates to (and its employees and agents) possession, access, use, disclosure, transmission, or release of any personally identifiable information (“PII”) and protected health information (“PHI”) of any individuals, including employees and agents. Provider represent and warrant that it if you have any access to PHI and PII, you have the legal authority under the Laws to possess, have access to, transmit and disclose the PII and PHI. Provider acknowledges and agrees that (i) you shall be responsible for any and all costs, fines, penalties, fees or expenses, including attorneys’ fees, related to any security incident, data breach, unauthorized access, unauthorized disclosures or unauthorized use of PHI caused by your or your staff’s, agents, or contractors (collectively, a “Security Incident”); and (ii) you shall hold harmless, defend, and indemnify NORTHWIND from any Security Incident or violation of any Laws. “Laws” is defined as all applicable international, federal and state laws, rules and regulations, including, but not limited to, any laws or regulations governing (a) the privacy and security of PHI or PII, including the Health Insurance Portability and Accountability Act of 1996, as amended (HIPAA); (b) the delivery of and billing of health care services, including, but not limited to, telehealth or telemedicine services; and, (c) the retention of health or other related records.

You acknowledge and agree that you have also been given an opportunity to review a copy of Northwind’s Privacy Policy. In order to utilize the Platform you will be requested to register with an email address and password (“User ID”). You are responsible for protecting your User ID and should not share you User ID with any other individuals.

Northwind’s Intellectual Property

You may not reproduce, distribute, display or transfer any portion of the Platform or content on the Platform for any commercial purpose. You may only print, download and store information from the Platform in compliance with all laws and in compliance with the Permitted Use. You acknowledge and agree that the Platform is protected by United States and international copyright, trademark, trade secret and other intellectual property rights. You may not copy, decompile, reverse engineer, disassemble or create derivative works of the Platform, or any part thereof. You may not submit any information on the Platform that would violate the intellectual property rights of third parties.

Limitation of Liability, Release, and Indemnification

The Platform and the Services provided by Northwind are provided on an “AS IS” and “AS AVAILABLE” basis, without any warranties of any kind, either express or implied. Northwind makes no express or implied warranties about the Platform or Services. To the maximum extent permitted by law, Northwind hereby disclaims all such warranties, including all statutory warranties, with respect to the Platform and the Services, including without limitation any warranties that the Platform or the Services are merchantable, of satisfactory quality, accurate, or fit for a particular purpose. Northwind does not guarantee that results may be obtained from the Platform. Northwind is not responsible for the accuracy, reliability, timeliness, or completeness of information provided by users of the Platform or any other data or information provided or received through the Platform.

You agree that Northwind shall not be liable for (a) any losses or damages arising from your use of the Platform or Services; or (d) any economic, incidental, consequential, indirect, special or punitive damages of any kind under any legal theory. You agree to hold harmless, release, defend, and indemnify Northwind from all liabilities, losses, and damages, including reasonable attorneys’ fees related to your use of the Platform or the Services. The foregoing indemnification obligation does not apply to liabilities, losses, and damages arising solely from the intentional misconduct or negligence of Northwind. No action arising under or in connection with this Agreement or your use of the Platform may be brought by you more than one (1) year after the claim or cause of action arose.

Miscellaneous

If any part of this Agreement is found to be unenforceable, illegal, or invalid, the remaining provisions of this Agreement shall remain unimpaired and enforceable. The headings utilized in this Agreement are for convenience only and in no way limit, define, modify, or describe the meaning, scope, or intent of this Agreement or any terms or conditions therein. These terms may be revised and updated from time to time. All changes are effective immediately when posted to the Platform. Your continued use of the Platform following the posting of a revised Agreement means that you agree and accept all changes. This Agreement and performance under it shall be governed by and construed in accordance with the laws of State of Indiana without regard to its choice of law principles. You hereby submit and consent to the exclusive jurisdiction of any state or federal court located within Marion County, Indiana as it relates to any disputes, lawsuits, claims, or causes of action related to this Agreement, the Platform, or the Services.

[ACKNOWLEDGEMENT]