a product of J. Knipper and Company, Inc.
J. Knipper and Company, Inc. ("Knipper") is committed to implementing appropriate
policies, procedures and information systems to preserve and safeguard your right
to privacy. As part of this commitment, we want you to be fully aware of what happens
sets out the manner in which we will collect, use, disclose and otherwise manage
- Why we collect Information
- What Information is collected
- How the Information is used
- With whom Information is shared
- Security of Personal Information
- Correcting or Updating Information
- How to Contact Us
its website and mobile application.
WHY WE COLLECT INFORMATION
Knipper's business is to provide pharmaceutical marketing services to pharmaceutical
companies, including manufacturers of over-the-counter and prescription pharmaceutical
products ("OTC and Rx Products"), and healthcare organizations. Knipper's marketing
services include: direct mail, DTC/DTP programs, kit design and assembly, web-ordering,
e-survey programs, e-sampling and fulfillment, and telemarketing fulfillments, among
others. In providing such services, the pharmaceutical companies, healthcare organizations
and/or Knipper may be required to obtain and use your personal information.
Knipper's online sampling application MySampleCloset.com® and its
mobile application counterpart collects Health Care Practitioner (HCP)-specific
information to enable pharmaceutical companies to offer unique sample promotions
based on the practitioner's specialty and to determine license verifications for
these targeted sample offers.
WHAT INFORMATION IS COLLECTED
In order to provide you with pharmaceutical marketing information such as information
relating to OTC and Rx Products, we collect both Personally Identifiable Information
(such as contact, public information, and demographic information described below)
and non-personally identifiable information such as "Traffic Data" (defined below)
using the methods listed below.
The type of product or service you seek on the Knipper website will determine the
personal information that is collected. In the course of providing pharmaceutical
marketing services, Knipper collects Personally Identifiable Information you provide
us when you:
- Request that we send you Discount Coupons for OTC or Rx Products;
- Request that we send you Rebate Coupons for the purchase of OTC or Rx Products;
- Request that we send you a Rebate Check in connection with OTC or Rx Products which
you have purchased;
- Request that we send you Trial Samples of OTC Products;
- Respond to one of our Surveys;
- Request that we send you Information about OTC or Rx Products;
- Participate in a Research Project which we coordinate on behalf of one of our Pharmaceutical
Company clients; or
- Enroll in a Patient Assistance Program which we coordinate on behalf of one of our
Pharmaceutical Company clients.
- Request a drug, medical device, literature or other items available on MySampleCloset®
or other Knipper provided websites.
When you take any of the above actions, we may collect Personally Identifiable Information
from you such as your name, age, address, telephone number, e-mail address, state
license, year of graduation and school of graduation.
Personally Identifiable Information may also be collected when you register at Knipper's
MySampleCloset.com® (including via MySampleCloset.com Mobile applications),
or provide your information to others such as pharmaceutical companies, medical
devices companies, e-commerce websites and healthcare organizations, including by
registering on their websites. Knipper's registration form may, from time to time,
require you to give us basic contact information (such as your name, mailing and
e-mail address) and some demographic information (such as your zip code, age and
gender). The information requested by Knipper's registration form may change from
time to time. Although additional demographic information may be requested at the
time of registration, only information marked "required" is necessary for you to
register on Knipper's website and take advantage of the promotional offers made
available thereon from time to time. With respect to your visits to our website,
we may automatically collect general anonymous information related to your use of
the website, such as the date and time you visit the website and the pages you visit
as well as collecting "cookie" information from your browser to identify your computer
and provide us with a record of your visits to our website (collectively, "Traffic
Data"). The technology used to gather "cookie" information is provided by the Internet
browser you use, and may be turned off by using your browser preference buttons.
Practitioner information collected on MySampleCloset.com® : When
an HCP becomes a registered user on the Knipper website, or chooses to interact
with the website in other ways (including via MySampleCloset.com Mobile applications),
Knipper collects certain personal information. The practitioner data collected on
the Knipper website may include his or her name, address, phone number and e-mail
address. Additional information that is practitioner-specific may also include demographic,
educational and professional information (state licensure numbers and DEA numbers)
which may later be used for the specific purpose of credentials verification for
specific sample programs, marketing, educational or detailing campaigns offered
by the pharmaceutical companies or directly by J. Knipper and Company Inc.
HOW THE INFORMATION IS USED
Knipper uses the Personally Identifiable Information that you provide to us for
the purposes of: (a) providing you with information, discount coupons, rebate coupons,
rebates, trial samples, prescription refill reminders and other marketing and non-marketing
communications relating to OTC, medical devices and/or Rx Products; (b) responding
to your requests; and (c) generally communicating with you. Knipper only uses or
discloses your Personally Identifiable Information or as permitted by law or authorized
Knipper engages in e-mail and direct mail marketing for its own products / services
and on behalf of pharmaceutical companies and healthcare organizations. E-mail or
direct mail address lists for these marketing campaigns are compiled from information
provided by you as set out above and/or based upon information by pharmaceutical
companies or healthcare organizations. In order to receive an e-mail message or
a direct mail communication that is part of a marketing campaign created by Knipper
or sent by Knipper on behalf of a Pharmaceutical Company or Health Care Organization,
you chose to be included on an e-mail or direct mail address list or chose to receive
e-mail or such direct mail communication from us. You may choose not to receive
future e-mail or direct mail communications from us (see Opt-Out Policy below).
The Traffic Data helps us to understand how our Website and mobile applications
are used (e.g., which pages or sections are most popular and when the peak activity
times occur) and to assist us in planning for future improvements to the website
to better meet your needs.
HCP's personal information may be used for the following purposes:
- to register the practitioner for programs and services the practitioner requested
- process, fulfill and follow-up on drug sample orders or literature requests
- respond to practitioner e-mails
- information requested by the practitioner
- ensure that MySampleCloset.com® is relevant to practitioner needs
- deliver notices for relevant meetings or events
- notify the practitioner about new products, services, and other related information
from Knipper and approved third parties
WITH WHOM INFORMATION IS SHARED
Knipper will not share your Personally Identifiable Information, including your
Protected Health Information except as authorized by you, permitted by applicable
law or described below.
Knipper may share your Personally Identifiable Information with pharmaceutical companies
or healthcare organizations in order to customize marketing and non-marketing communications
and provide you with information, discount coupons, rebate coupons, rebates, product
details, continued medical education programs, patient assistance programs, trial
samples and prescription refill reminders relating to medical devices, OTC and/or
Rx Products in which you are interested.
Knipper may share your Personally Identifiable Information, including your Protected
Health Information, on a confidential basis with third party service providers that
we retain from time to time to perform work on our behalf. These third party service
providers are not authorized to use or disclose this information for any purpose
other than to perform services on Knipper's behalf.
Knipper may disclose your Personally Identifiable Information or Protected Health
Information when it believes the disclosure is appropriate to comply with applicable
law; or to protect the rights, property and safety of (i) Knipper, (ii) those persons
who disclose their Personally Identifiable Information or Protected Health Information
to us, or (iii) others. We must provide your Personally Identifiable Information,
including your Protected Health Information: (a) in response to a search warrant
or other legally valid inquiry or order; (b) to an authorized investigative body
in response to their inquiry; (c) in the case of a breach of an agreement or contravention
of law; or (d) as otherwise required by law.
The Knipper website may include links to third party websites. These linked sites
have separate and independent privacy policies. Knipper has no control over such
sites and therefore has no responsibility or liability for the manner in which the
organizations which operate such linked sites may collect, use or disclose and otherwise
treat your personal information.
SECURITY OF PERSONAL INFORMATION
Knipper is committed to implementing appropriate policies and procedures to maintain
your personal information in secure data storage to safeguard it from unauthorized
access, use or disclosure and maintain the strict confidentiality of all personal
information collected. Knipper will only disclose such information to the pharmaceutical
companies or healthcare organizations who are our clients, Knipper employees and
third party service providers who require such information for the purposes set
out above. We will only keep your personal information for as long as it remains
necessary or relevant for the purposes stated above or as otherwise required by
User ID and Password:MySampleCloset.com requires the use of a user ID and password
as a supplementary security measure to help protect practitioner information. The
user ID and password allow Knipper to verify who you are, thus permitting access
to your account information and preventing unauthorized access.
Unfortunately, no data transmission over the Internet can be guaranteed 100% secure.
Accordingly, and despite our diligent efforts, Knipper cannot guarantee or warrant
the security of any information you transmit to us, or to or from our online products
OPTING - OUT
If Knipper has collected your Personally Identifiable Information or Protected Health
Information, Knipper will process your election to opt-out. If however, someone
other than Knipper has collected that information, you must contact that other person
to opt-out. If you would like to opt-out, that is to withdraw your authorization
to the use and/or disclosure of your Personally Identifiable Information or Protected
Health Information which Knipper has collected, you may do so at any time by notifying
us of your decision to opt-out. You may provide such notification by writing to
us at J. Knipper and Company, Inc., Attention: Privacy Officer, One Healthcare Way,
Lakewood, New Jersey 08701. Please be certain to include the name of the program
in question. You must provide the name of the program, proof of your identity (a
copy of your license or a notarized letter with your name, professional designation,
address and telephone number) to ensure proper identity of person making a request.
CORRECTING OR UPDATING INFORMATION
If you would like to correct or update any of your Personally Identifiable Information
or Protected Health Information we have in our possession, please write to us at
J. Knipper and Company, Inc., Attention: Privacy Officer, One Healthcare Way, Lakewood,
New Jersey 08701. Please be certain to include the name of the program in question.
You must provide the name of the program, proof of your identity (a copy of your
license or a notarized letter with your name, professional designation, address
and telephone number) to ensure proper identity of person making a request.
Knipper reserves the right, at any time and without notice, for any reason, to add,
change, modification or revision on its website at www.Knipper.com. Any such addition,
update, change, modification or revision will be effective immediately upon posting
on the website. You will have a choice and may notify us if you do not wish us to
use your information in this different manner (See "Opting-Out"). Knipper may use
in effect from time to time.
THIS PRIVACY NOTICE, AS REQUIRED BY THE CALIFORNIA CONSUMER PRIVACY ACT OF 2018 (“CCPA”),
RESIDE IN THE STATE OF CALIFORNIA. (THE FOLLOWING ARE ADDRESSED IN THE ABOVE PRIVACY
POLICY: HOW KNIPPER COLLECTS YOUR PERSONAL INFORMATION; USE OF YOUR PERSONAL
INFORMATION; NON-DISCRIMINATION; CHANGES TO THIS POLICY)
TYPES OF PERSONAL INFORMATION COLLECTED BY KNIPPER BY CATEGORY
CCPA Category of Personal Information
Collected by Knipper in the last 12 months
Name, postal address, unique personal identifier, online identifier, Internet Protocol(IP)
address, email address, and other similar identifiers
Name, signature, address, telephone number, education, employment
Protected classification characteristics under California or federal law.
Records of products or services ordered or purchased or those which you have access
to order or purchase,
Internet or network activity.
Information regarding a consumer’s interaction with our websites, application, or
advertisement, passwords and pins created to access our websites
Geographic location based on URL
Professional or employment-related information.
DEA#s, SLN#s, SAN #s; employee ID#; healthcare provider designations, and/or specialties;
employee territories, employers, managers
Non-public education information
Knipper may make certain inferences from individual or combined pieces of Information
in (i) –(x)
Personal Information does not include:
Personal information does not include: Publicly available information from government
records; De-identified or aggregated consumer information; health or medical information
covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA)
or similar state statutes; personal information covered by certain sector-specific
privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley
Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's
Privacy Protection Act of 1994.
DISCLOSURES OF PERSONAL INFORMATION IN LAST 12 MONTHS
- Knipper does not collect information from minors.
- Knipper does not sell any information referenced above.
- In the preceding twelve (12) months, Knipper has not sold any information referenced
- In the preceding twelve (12) months, Knipper has disclosed the following categories
of personal information for a business purpose: (i), (ii), (iv), (vi), (vii), (ix),
- Knipper only discloses your personal information as required by law or for a business
purpose to our affiliates, service providers and third parties where you, your employer,
or your agent(s), have authorized that disclosure.
YOUR RIGHTS UNDER THE CCPA
CCPA ACCESS RIGHTS
You have the right to request that Knipper disclose certain information to you about
our collection and use of your Personal Information over the past 12 months. Once
Knipper receives and confirms your verifiable consumer request, Knipper will disclose
- The categories of Personal Information that Knipper collected about you.
- The categories of sources for the Personal Information that Knipper collected about
- Knipper’s business or commercial purpose for collecting or selling that Personal
- The categories of third parties with whom Knipper shared that Personal Information.
- The specific pieces of Personal Information Knipper collected about you (also called
a data portability request).
- If Knipper disclosed your Personal Information for a business purpose, identifying
the Personal Information categories that each category of recipient obtained.
CCPA DELETION RIGHTS
You have the right to request that Knipper delete your Personal Information, subject
to certain exceptions. Once Knipper receives and confirms your verifiable consumer
request, we will delete (and direct our service providers to delete) your Personal
Information from our records, unless an exception applies.
Knipper may deny your deletion request if retaining the information is necessary
for us or our service provider(s) to:
- Complete the transaction for which Knipper collected the Personal Information, provide
a good or service that you requested, take actions reasonably anticipated within
the context of our ongoing business relationship with you, or otherwise perform
our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or
illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise a right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code
§ 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research
in the public interest that adheres to all other applicable ethics and privacy laws,
when the information’s deletion may likely render impossible or seriously impair
the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations
based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with
the context in which you provided it.
CCPA PORTABILITY RIGHTS
To exercise the access, data portability, and deletion rights described above, please
submit a verifiable consumer request to us by contacting us at 1-888-564-7737 or
firstname.lastname@example.org. Only you, or a person registered with the California Secretary
of State that you authorize to act on your behalf, may make a verifiable consumer
request related to your Personal Information. You may also make a verifiable consumer
request on behalf of your minor child. You may only make a verifiable consumer request
for access or data portability twice within a 12-month period. The verifiable consumer
- Provide sufficient information that allows Knipper to reasonably verify you are
the person about whom Knipper collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand,
evaluate, and respond to it.
Knipper cannot respond to your request or provide you with Personal Information
if Knipper cannot verify your identity or authority to make the request and confirm
the Personal Information relates to you.
Knipper will only use Personal Information provided in a verifiable consumer request
to verify the requestor’s identity or authority to make the request.
CCPA REQUESTS, RESPONSES, AND TIMING
Knipper will try to respond to a verifiable consumer request within forty-five (45)
days of its receipt. If Knipper requires more time, Knipper will inform you of the
reason and extension period in writing. Knipper will deliver our written response
by mail or electronically, at your option. Any disclosures Knipper provides will
only cover the 12-month period preceding the verifiable consumer request’s receipt.
The response Knipper provides will also explain the reasons Knipper cannot comply
with a request, if applicable. For data portability requests, Knipper will select
a format to provide your Personal Information that is readily useable and should
allow you to transmit the information from one entity to another entity without
hindrance. Knipper does not charge a fee to process or respond to your verifiable
consumer request unless it is excessive, repetitive, or manifestly unfounded. If
Knipper determines that the request warrants a fee, Knipper will tell you why Knipper
made that decision and provide you with a cost estimate before completing your request.
HOW TO CONTACT US
us at 1-888-564-7737 or write to us at J. Knipper and Company, Inc., Attention:
Privacy Officer, One Healthcare Way, Lakewood, New Jersey 08701.
J. Knipper and Company, Inc. All rights reserved.