Privacy Policy

We use data to bring you personalized offers and deals.
The Privacy Policy covers the type of data we collect and how we use it, as well as your rights as a consumer. Please don’t hesitate to contact with any questions.
Privacy Policy
Last Updated: July 1, 2022

This Privacy Policy describes how HomeTown Pharmacy (“HomeTown,” “we” or “us”) may collect, use, share and protect information about you through your interactions with us in our stores, or on our websites, mobile applications, any other HomeTown affiliate websites where you interact with Hometown, you consent to practices described in this Privacy Policy. If you have any questions or concerns about this Privacy Policy, or about the way your information is collected and used, please call us at (231) 861-6900.

Any changes in our Privacy Policy will appear on this page so that you are aware of the data we collect and how we use it. We will notify you of material changes to this Privacy Policy by posting on our websites notification that the Privacy Policy has been revised and by updating the effective date of the Privacy Policy.
In some circumstances, HomeTown’s use of your information will be subject to the requirements of the Health Information Portability and Accountability Act (commonly known as “HIPAA”). For example, if you log in to your pharmacy account and submit information regarding a prescription order, that information is subject to HIPAA’s requirements. In those circumstances, the HomeTown’s Notice of Privacy Practices and not this Privacy Policy will apply. If you have questions about which policy applies to the information you have submitted, please do not hesitate to contact us.

Our Privacy Program
At HomeTown, we are committed to maintaining our customers’ privacy. We take great care to safeguard the information that we collect to maintain our customers’ privacy. We have provided this Privacy Policy to you to describe information collection and use practices at HomeTown. This Privacy Policy describes the choices you can make about the way your information is collected and used.

Information We Collect
We want you to understand how personal information you provide to us is collected and used. Personal information is any information that we can use to identify, locate, or contact you. We may collect and store your personal information when you provide it to us or to our service providers.
Some examples of personal information we collect and when we collect it includes:
• when you register for accounts on our website or mobile applications
• when you participate in promotions, surveys or contests that we offer or administer
• when you enroll in or participate in one of our loyalty programs or redeem coupons or offers from us
• when you indicate that you are interested in receiving information about our products or services, such as e-mail alerts, newsletters, and other notifications
• transaction information about how you interact with us such as purchase history, when you make returns or exchanges, request an e-receipt, arrange to pick up your retail order, or have your order delivered to your home
• your interactions with our websites or mobile sites, mobile applications, Wi-Fi, and other online services
• how you use our sites and mobile applications, search terms, pages you visit on our mobile applications, computer and mobile device information and push notification services you request
• when you request that merchandise be sent to you or others we store billing and shipping information as a convenience to you for future purchases, and we will store information about your orders for order tracking and status retrieval purposes
• when you purchase an item from us, we will collect your financial information, such as your credit or debit card information, to process the payment
• precise location information if you provide it to us (for example to show you the store nearest you) or authorize us to collect it in our stores (e.g., to help you find a product)
• general location information from your browser or device, which we use for internal purposes only
• your social media account information if you share it with us (e.g., Facebook ID)
If you choose not to provide your personal information to us, we may not be able to provide you with requested products, services, or information.
Information you provide to us directly, including when you:
• Make an in-store or online purchase, or other transaction with us.
• Create an account on one of our websites or mobile application .
• Participate in our loyalty programs.
• Participate in a contest, promotion, or survey.
• Correspond directly with us, such as through our websites, postal mail, customer service, or dispute resolution mechanisms; or
• Post a review or comment on one of our websites, or post other user-generated content on one of our websites or mobile application.

Information we collect when you use our services, including:

Device Information
• We may collect device-specific information when you visit our websites or use our mobile application or services. This includes information such as Internet Protocol (IP) address, hardware model, operating system, unique device identifiers, mobile network information, location data such as zip code, the address of referring websites, the path you take through our websites, and other information about your session on our websites. We may also associate the information we collect from your different devices, which helps us provide consistent services across your devices.

Log Information
• This includes details of how you used our websites or mobile applications including clicks and page information such as the address (or URL) of the website or mobile application you came from before visiting our website or mobile application, which pages you visit on our website or mobile application, which browser you used to view our website or mobile application, and any search terms entered.
• Other information from your interaction with our websites, services, content and advertising, including computer and connection information, statistics on page views, traffic to and from the websites, ad data and other standard weblog information.
Precise Location Information
• When you use our services on your mobile phone or device and enable location services on your mobile phone or device browser, we may collect information about your physical location through satellite, cell phone tower, Wi-Fi signal, beacons, Bluetooth and near field communication protocols (“precise location information”). If you use our mobile application, your device may share precise location information when you enable location services for our application. To learn how to opt-out of sharing your precise location information with HomeTown, go to the “Your Choices” section of this Privacy Policy. When you use our mobile application, we may also request access to your Bluetooth signal from your device. If you enable our mobile application to use your Bluetooth signal, we may be able to determine your device’s in-store location. To learn how to opt-out of sharing your device’s Bluetooth signal with HomeTown, go to the “Your Choices” section of this Privacy Policy.

In-Store Cameras
• We use in-store cameras for security purposes and for operational purposes such as measuring traffic patterns and tracking in-stock levels.
Cookies, Web Beacons and Similar Technologies
• “Cookies” are small data files that are sent from a website’s server and are stored on your device’s hard drive either for only the duration of your visit (“session cookies”) or for a fixed period (“persistent cookies”). Cookies may store user preferences and other types of information. We use cookies to provide features and services, such as:
– Remembering your preferences and allowing you to enter your username less frequently.
– Presenting information that’s targeted to your interests, including HomeTown content presented on another website;
– Measuring the effectiveness of our websites, services, content and advertising; and
– Providing other services and features that are available only through the use of cookies.
• The Options/Settings section of most internet browsers will tell you how to manage cookies and other technologies that may be transferred to your device, including how to disable these technologies. You can disable our cookies or all cookies through your browser setting, but please note that disabling cookies may impact some of our website’s features and prevent the website from operating properly.
• A “Web Beacon” is an electronic image placed in the code of a webpage, application, or email. We use web beacons to monitor the traffic patterns of users from one page to another and to improve website performance, and in our emails to understand when our email communications are opened or discarded.

Flash Cookies
• We may use or engage a third party that uses Local Stored Objects, sometimes referred to as “Flash Cookies,” and other technologies to collect and store information about the use of our services. A Flash cookie is a small data file placed on your computer or device using Adobe Flash technology. Flash cookies are different from the cookies discussed above because cookie management tools provided by your browser will not remove Flash cookies. To limit the websites that can store information in Flash cookies on your device, you must visit the Adobe website.

Information We Collect from Other Sources

We may collect information that is publicly available. For example, we may collect information you submit to a blog, chat room, or social network. We also may collect information from other companies, organizations, or third-party partners. For example, we may receive information about you from a partner when we jointly offer services or from an advertiser about your experiences with them. By gathering additional information about you, we can correct inaccurate information and give you product recommendations and special offers more likely to interest you.
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How We Use Your Information
Our primary purpose in collecting information is to provide you with a safe, smooth, efficient, and customized experience. We may use your information in a variety of ways, including for the following purposes:
Product and Service Fulfillment
• We use your contact information to respond to your inquiries, fulfill your requests and improve your experience.

Our Marketing Purposes
• We use your information to deliver coupons, mobile coupons, newsletters, emails, mobile messages, and social media notifications about our brands, products, events, or other promotional purposes.
• We use your information for reporting and analysis purposes. We examine metrics such as how you are shopping on our website, in our stores, and on our mobile applications, the performance of our marketing efforts, and your response to those marketing efforts.
• We use your information to administer promotions, surveys, and focus groups.
• We use your information to enable Online Tracking and Interest Based Advertising as further described in this Privacy Policy.
• We use your information to improve your experiences when you interact with us.
• We use your Precise Location Information to provide location-based services for these marketing purposes. For example, using the Store Locator feature in our mobile application can allow you to quickly find the nearest HomeTown location.

Internal Operations
• We use your information to improve the effectiveness of our services, conduct research and analysis, or to perform other business activities as needed.
Prevention of Fraud and other Harm
• We use your information to detect, prevent or investigate potential security breaches, fraudulent transactions and monitor against theft.
Legal Compliance and As Necessary or Appropriate Under Applicable Law
• We may use your information as necessary or appropriate under applicable law, to comply with legal process, to respond to such requests from public and government authorities (including law enforcement), to enforce our terms and conditions, including investigations of potential violations, to detect, prevent or otherwise address fraud, security or technical issues, to protect our rights, privacy, safety or property, and to allow us to pursue available remedies to limit the damages that we may sustain. In matters involving claims of personal or public safety or in litigation where the data is pertinent, we may use personal information without your consent or court process.
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How We Share Your Information:
While we do not directly sell, rent, or loan your personally identifiable information, we may share your information with companies, organizations, and individuals outside of HomeTown as described below. Please note that certain state laws have adopted a broad definition of a “sale” and may treat certain of these disclosures as sales under their definitions

Internally
• We may share your information with our parent company or affiliates, including but not limited to, HomeTown Boots Alliance Inc., Boots Retail USA Inc., HomeTown Specialty Pharmacy Holdings, LLC, and HomeTown Specialty Pharmacy, LLC DBA Alliance Rx HomeTown Pharmacy.
When We Work with Third Parties
• We may share your information with affiliated and unaffiliated companies that perform tasks on our behalf related to our business. Such tasks include analyzing website usage data, customer service, electronic and postal mail service, and social and other media services.
• We may work with other companies who place cookies, tags, and web beacons on our websites. These companies help operate our websites and provide you with additional products and services.
• We may also use third-party advertising networks to serve advertisements on our behalf. The cookies received with the banner advertisements served by these networks may be used to collect and build behavioral profiles by these companies to deliver targeted advertisements on our website and unaffiliated websites.
• We may work with other companies who operate their own websites or mobile applications, to allow them to offer HomeTown customers the ability to connect to HomeTown services. These services give you more options for ways to use HomeTown services from websites or applications that are not owned or operated by HomeTown.
• We contract with partner companies to allow HomeTown customers to access one of their loyalty programs accounts from those partners’ websites and/or mobile applications. This may include the ability to join a loyalty program, add an existing membership, and/or access your account balance.
• If you participate in a loyalty program component which permits you to connect your loyalty program accounts with websites, application, and devices, including non-HomeTown partners and their websites, application, and devices. Notwithstanding the uses and disclosures set forth above, HomeTown may use or disclose personally identifiable information gathered under one of its loyalty programs for improving health, health research, or with your consent.
• Social Media: Our online services may use social media plugins (e.g., the Facebook “Like” button, “Share to Twitter” button) to enable you to easily interact with certain social media websites (e.g., Facebook, Twitter, Instagram) and share information with others. When you visit our services, the operators of the available social media plugins can place a cookie on your device enabling such operators to recognize individuals who have previously visited our services. If you are logged in to these social media websites while visiting our services, the social media plugins allow the relevant social media websites to receive information that you have visited our services or other information. The social media plugins also allow the applicable social media websites to share information about your activities on our services with other users of the social media website. We do not control any of the content from the social media plugins. We may also interact with you on social media platforms. If you contact us on one of our social media platforms, request services, or otherwise communicate directly with us on social media, we may contact you to interact with you. For more information about social media advertising and social media plugins from other social media websites, please refer to those websites’ privacy and data sharing statements.
• We may share your information with business partners who may offer services or products to you. For example, in connection with the HomeTown credit card, we share some information with our partner so it can prescreen individuals to see if they qualify for offers. You can learn about your rights relating to prescreened offers including how to opt out by calling 1-888-567-8688 or by going here.
When Sharing is Required by Law or Helps Us Protect Our Interests
• We will disclose your information as necessary or appropriate under applicable law, to comply with legal process, to respond to such requests from public and government authorities, to enforce our terms and conditions, including investigations of potential violations, to detect, prevent or otherwise address fraud, security, or technical issues, to protect our rights, privacy, safety, or property, and to allow us to pursue available remedies to limit the damages that we may sustain. In matters involving claims of personal or public safety or in litigation where the data is pertinent, we may use or disclose personal information without your consent or court process.

When We Work on Business Transactions
• As we continue to develop our business, we might sell or buy stores or assets, or engage in mergers, acquisitions, or sale of company assets. Personal information may be disclosed in connection with the evaluation of or entry into such transactions or related business arrangements, or while providing transition of services to another entity as permitted by law. In such transactions, customer information generally is one of the transferred business assets. Additionally, if HomeTown or substantially all of its assets are acquired, customer information will likely be one of the transferred assets as is permissible under law.
Non-identifiable or Aggregate information with Third Parties
• We may share non-identifiable or aggregate information with third parties for lawful purposes.
With Your Consent
• At your direction or request, or when you otherwise consent, we may share your information.
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Your Choices
By interacting with any of the HomeTown family of companies as described herein, you consent to the practices described in this Privacy Policy. However, we want you to know that you do have certain choices about how your information is collected and used.
Email and Mobile Communications
• You may choose to stop receiving email and mobile marketing communications by changing your preferences online. If you have an online account, log in to Your Account and click on Communication Preferences. If you do not have an online account, you may click Unsubscribe from the bottom of HomeTown emails, and reply STOP to our text messages to stop receiving emails and SMS text messages. To request unsubscribing by email, contact Customerservice@HomeTown.com.
Mobile Application
• Push Notifications
You can opt out from further allowing HomeTown to send you push notifications by adjusting the permissions in your mobile device or from the HomeTown mobile application.
• Precise Location Data
You can opt out from further allowing HomeTown to access precise location data by adjusting the permissions in your mobile device.
• In-Store Location
You can opt out from further allowing HomeTown to access your Bluetooth signal in our stores by adjusting the location permissions in your mobile device or from the HomeTown mobile application.
Online Tracking and Interest-Based Advertisements
• HomeTown engages third-party advertisers to provide interest-based advertising on our website, as well as other third-party websites to display advertising that is relevant to you. These third parties may collect information about your use of our services over time and that information may be combined with information collected on different websites and online services. These third-party advertisers may be participants in the Network Advertising Initiative and/or the Self-Regulatory Program for Online Behavioral Advertising, which allow users to opt out of ad targeting from participating companies. To learn more about interest-based advertising, or to opt out of having your web browsing information used by certain third-party advertisers for behavioral advertising purposes, click here.
Please Note: When you “opt out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from HomeTown. It means that the online ads that you do see will not be tailored for you based on your interests. We may still collect information about you for any purpose permitted under the Policy, including for analytics and fraud prevention.

Our “Do Not Track” Policy
• HomeTown respects enhanced user privacy controls. We support the development and implementation of a standard “do not track” browser feature, which signals to websites that you visit that you do not want to have your online activity tracked. Please note that currently HomeTown.com does not interpret or respond to “do not track” signals. However, you may set your Web browser to not accept new cookies or web beacons, be notified when you receive a new cookie, or disable cookies altogether. Please note that by disabling these features, your experience on HomeTown.com will not be as smooth and you will not be able to take full advantage of our website’s features. Please see the Help section of your browser for instructions on managing security preferences.
Minors
• If you are under 18 years old and a registered user, you can request that we remove content or information that you have posted to our website or other online services. Note that fulfilment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another user). To request removal of content or information, please contact us.
Accessing and Updating Your Personally Identifiable Information
• You can review and update any of the information you have given us by emailing us or calling 877-924-4472. Our customer care staff will update your information. If you have a HomeTown.com account, you can log in and update your information.

Links to Third-Party Websites
• Our services may contain links to, or otherwise make available, social media websites and other third-party services, websites and mobile applications that are operated and controlled by third parties. We do not take responsibility for the content or the privacy practices employed by other websites. Unless otherwise stated, any Information you provide to any such third-party website will be collected by that party and not by HomeTown and will be subject to that party’s privacy policy (if any), rather than this Privacy Policy. In such a situation, we will have no control over, and shall not be responsible for, that party’s use of the Information you provide to them.
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How We Protect Your Information
Security Measures
• HomeTown recognizes the importance of maintaining the security of your information. Whether you are shopping on our website, through our mobile services, or in our stores, we use reasonable security measures, including administrative, technical, and physical safeguards.
Email Security
• “Phishing” is a common email scam where your email address is used to contact you and ask for personally identifiable or sensitive information. Always be cautious when opening links or attachments from unsolicited third parties. Also know that HomeTown will not send you emails asking for your credit card number, social security number or other personally identifiable information. If you are ever asked for this information, you can be confident it is not from HomeTown.
Children’s Personal Information
• We recognize the importance of protecting children’s online privacy. Our website and mobile services are intended for a general audience and are not directed to children. We do not knowingly collect personal information online from children under the age of 13.
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The Privacy Policy covers the type of data we collect and how we use it, as well as your rights as a consumer. Please don’t hesitate to contact us with any questions.
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HomeTown Privacy & Security Policy
Last Updated: September 25, 2021
This Privacy Policy lets you know how we collect, use, share, and protect information about you. By interacting with HomeTown through our stores, websites, mobile applications, and any other HomeTown affiliate websites where you may interact with HomeTown, you consent to the practices described in this Privacy Policy. Any changes in our Privacy Policy will appear on this page so that you are aware of the data we collect and how we use it. We will notify you of material changes to this Privacy Policy by posting on our websites notification that the Privacy Policy has been revised and by updating the effective date of the Privacy Policy.

In some circumstances, HomeTown’ use of your information will be subject to the requirements of the Health Information Portability and Accountability Act (commonly known as “HIPAA”). For example, if you log in to your pharmacy account and submit information regarding a prescription order, that information is subject to HIPAA’s requirements. In those circumstances, the HomeTown Notice of Privacy Practices and not this Privacy Policy will apply. If you have questions about which policy applies to the information you have submitted, please do not hesitate to Contact Us.

Information We Collect
We want you to understand how information you provide to us is collected and used. When you interact with HomeTown or use our services, we collect certain information about you and the services you use. An example of using our “services” would be when you visit one of our stores or websites. We may collect and store information from you in the following situations:
Information you provide to us directly, including when you:
• Make an in-store or online purchase, or other transaction with us;
• Create an account on one of our websites or mobile application;
• Participate in our loyalty programs;
• Participate in a contest, sweepstake, promotion, or survey;
• Correspond directly with us, such as through our websites, postal mail, customer service, or dispute resolution mechanisms; or
• Post a review or comment on one of our websites, or post other user-generated content on one of our websites or mobile application.
Information we collect when you use our services, including:

Device Information
• We may collect device-specific information when you visit our websites or use our mobile applications or services. This includes information such as Internet Protocol (IP) address, hardware model, operating system, unique device identifiers, mobile network information, location data such as zip code, the address of referring websites, the path you take through our websites, and other information about your session on our websites. We may also associate the information we collect from your different devices, which helps us provide consistent services across your devices.

Precise Location Information
• When you use our services on your mobile phone or device and enable location services on your mobile phone or device browser, we may collect information about your physical location through satellite, cell phone tower, Wi-Fi signal, beacons, Bluetooth and near field communication protocols (“precise location information”). If you use our mobile application, your device may share precise location information when you enable location services for our application. To learn how to opt-out of sharing your precise location information with HomeTown, go to the “Your Choices” section of this Privacy Policy. When you use our mobile application, we may also request access to your Bluetooth signal from your device. If you enable our mobile application to use your Bluetooth signal, we may be able to determine your device’s in-store location. To learn how to opt-out of sharing your device’s Bluetooth signal with HomeTown, go to the “Your Choices” section of this Privacy Policy.

In-Store Cameras
• We use in-store cameras for security purposes and for operational purposes such as measuring traffic patterns and tracking in-stock levels.
Cookies, Web Beacons and Similar Technologies
• “Cookies” are small data files that are sent from a website’s server and are stored on your device’s hard drive either for only the duration of your visit (“session cookies”) or for a fixed period of time (“persistent cookies”). Cookies may store user preferences and other types of information. We use cookies to provide features and services, such as:
– Remembering your preferences and allowing you to enter your username less frequently;
– Presenting information that’s targeted to your interests, including HomeTown content presented on another website;
– Measuring the effectiveness of our websites, services, content and advertising; and
– Providing other services and features that are available only through the use of cookies.
• The Options/Settings section of most internet browsers will tell you how to manage cookies and other technologies that may be transferred to your device, including how to disable these technologies. You can disable our cookies or all cookies through your browser setting, but please note that disabling cookies may impact some of our website’s features and prevent the website from operating properly.
• A “Web Beacon” is an electronic image placed in the code of a webpage, application, or email. We use web beacons to monitor the traffic patterns of users from one page to another and to improve website performance, and in our emails to understand when our email communications are opened or discarded.

Information We Collect from Other Sources
We may collect information that is publicly available. For example, we may collect information you submit to a blog, chat room, or social network. We also may collect information from other companies, organizations, or third-party partners. For example, we may receive information about you from a partner when we jointly offer services or from an advertiser about your experiences with them. By gathering additional information about you, we can correct inaccurate information and give you product recommendations and special offers more likely to interest you.
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Our Marketing Purposes
• We use your information to deliver coupons, mobile coupons, newsletters, emails, mobile messages, and social media notifications about our brands, products, events or other promotional purposes.
• We use your information for reporting and analysis purposes. We examine metrics such as how you are shopping on our website, in our stores, and on our mobile applications, the performance of our marketing efforts, and your response to those marketing efforts.
• We use your information to administer promotions, surveys, and focus groups.
• We use your information to enable Online Tracking and Interest Based Advertising as further described in this Privacy Policy.
• We use your information to improve your experiences when you interact with us.
• We use your Precise Location Information to provide location based services for these marketing purposes. For example, using the Store Locator feature in our mobile application can allow you to quickly find the nearest HomeTown location.

How We Share Your Information:
While we do not directly sell, rent, or loan your personally identifiable information, we may share your information with companies, organizations and individuals outside of HomeTown as described below. Please note that certain state laws have adopted a broad definition of a “sale” and may treat certain of these disclosures as sales under their definitions.

Internally
• We may share your information with our parent company or affiliates, including but not limited to, HomeTown Boots Alliance Inc., Boots Retail USA Inc., HomeTown Specialty Pharmacy Holdings, LLC, and HomeTown Specialty Pharmacy, LLC DBA Alliance Rx HomeTown Pharmacy.
When We Work With Third Parties
• We may share your information with affiliated and unaffiliated companies that perform tasks on our behalf related to our business. Such tasks include analyzing website usage data, customer service, electronic and postal mail service, and social and other media services.
• We may work with other companies who place cookies, tags, and web beacons on our websites. These companies help operate our websites and provide you with additional products and services.
• We may also use third-party advertising networks to serve advertisements on our behalf. The cookies received with the banner advertisements served by these networks may be used to collect and build behavioral profiles by these companies to deliver targeted advertisements on our website and unaffiliated websites.
• We may work with other companies who operate their own websites or mobile applications, to allow them to offer HomeTown customers the ability to connect to HomeTown services. These services give you more options for ways to use HomeTown services from websites or applications that are not owned or operated by HomeTown.
• We contract with partner companies to allow HomeTown customers to access one of their loyalty program accounts from those partners’ websites and/or mobile applications. This may include the ability to join a loyalty program, add an existing membership, and/or access your account balance.
• If you participate in a loyalty program component which permits you to connect your loyalty program accounts with websites, application, and devices, including non-HomeTown partners and their websites, application and devices. Notwithstanding the uses and disclosures set forth above, HomeTown may use or disclose personally identifiable information gathered under one of its loyalty programs for improving health, health research, or with your consent.
• Social Media: Our online services may use social media plugins (e.g., the Facebook “Like” button, “Share to Twitter” button) to enable you to easily interact with certain social media websites (e.g., Facebook, Twitter, Instagram) and share information with others. When you visit our services, the operators of the available social media plugins can place a cookie on your device enabling such operators to recognize individuals who have previously visited our services. If you are logged in to these social media websites while visiting our services, the social media plugins allow the relevant social media websites to receive information that you have visited our services or other information. The social media plugins also allow the applicable social media websites to share information about your activities on our services with other users of the social media website. We do not control any of the content from the social media plugins. We may also interact with you on social media platforms. If you contact us on one of our social media platforms, request services, or otherwise communicate directly with us on social media, we may contact you to interact with you. For more information about social media advertising and social media plugins from other social media websites, please refer to those websites’ privacy and data sharing statements.
• We may share your information with business partners who may offer services or products to you. For example, in connection with the HomeTown credit card, we share some information with our partner so it can prescreen individuals to see if they qualify for offers. You can learn about your rights relating to prescreened offers including how to opt out by calling 1-888-567-8688 or click here.

When Sharing is Required by Law or Helps Us Protect Our Interests
• We will disclose your information as necessary or appropriate under applicable law, to comply with legal process, to respond to such requests from public and government authorities, to enforce our terms and conditions, including investigations of potential violations, to detect, prevent or otherwise address fraud, security or technical issues, to protect our rights, privacy, safety or property, and to allow us to pursue available remedies to limit the damages that we may sustain. In matters involving claims of personal or public safety or in litigation where the data is pertinent, we may use or disclose personal information without your consent or court process.

When We Work On Business Transactions
• As we continue to develop our business, we might sell or buy stores or assets, or engage in mergers, acquisitions, or sale of company assets. Personal information may be disclosed in connection with the evaluation of or entry into such transactions or related business arrangements, or in the course of providing transition of services to another entity as permitted by law. In such transactions, customer information generally is one of the transferred business assets. Additionally, in the event that HomeTown or substantially all of its assets are acquired, customer information will likely be one of the transferred assets as is permissible under law.

Non-identifiable or Aggregate information with Third Parties
• We may share non-identifiable or aggregate information with third parties for lawful purposes.
With Your Consent
• At your direction or request, or when you otherwise consent, we may share your information.
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Email and Mobile Communications
• You may choose to stop receiving email and mobile marketing communications by changing your preferences online. If you have an online account, log in to Your Account and click on Communication Preferences. If you do not have an online account, you may click Unsubscribe from the bottom of HomeTown emails, and reply STOP to our text messages to stop receiving emails and SMS text messages. To request unsubscribing by email, contact Customerservice@HomeTown.com.

Mobile Application
• Push Notifications
You can opt out from further allowing HomeTown to send you push notifications by adjusting the permissions in your mobile device or from the HomeTown mobile application.
• Precise Location Data
You can opt out from further allowing HomeTown to access precise location data by adjusting the permissions in your mobile device.
• In-Store Location
You can opt out from further allowing HomeTown to access your Bluetooth signal in our stores by adjusting the location permissions in your mobile device or from the HomeTown mobile application.

Online Tracking and Interest-Based Advertisements
• HomeTown engages third-party advertisers to provide interest-based advertising on our website, as well as other third-party websites in order to display advertising that is relevant to you. These third parties may collect information about your use of our services over time and that information may be combined with information collected on different websites and online services. These third-party advertisers may be participants in the Network Advertising Initiative and/or the Self-Regulatory Program for Online Behavioral Advertising, which allow users to opt out of ad targeting from participating companies. To learn more about interest-based advertising, or to opt out of having your web browsing information used by certain third-party advertisers for behavioral advertising purposes, click here.

Please Note: When you “opt out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from HomeTown. It means that the online ads that you do see will not be tailored for you based on your particular interests. We may still collect information about you for any purpose permitted under the Policy, including for analytics and fraud prevention.

Our “Do Not Track” Policy
• HomeTown respects enhanced user privacy controls. We support the development and implementation of a standard “do not track” browser feature, which signals to websites that you visit that you do not want to have your online activity tracked. Please note that at this time HomeTown.com does not interpret or respond to “do not track” signals. However, you may set your Web browser to not accept new cookies or web beacons, be notified when you receive a new cookie, or disable cookies altogether. Please note that by disabling these features, your experience on HomeTown.com will not be as smooth and you will not be able to take full advantage of our website’s features. Please see the Help section of your browser for instructions on managing security preferences.
Minors
• If you are under 18 years old and a registered user, you can request that we remove content or information that you have posted to our website or other online services. Note that fulfilment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another user). To request removal of content or information, please contact us.
Accessing and Updating Your Personally Identifiable Information
• You can review and update any of the information you have given us by emailing us or calling 877-924-4472. Our customer care staff will update your information. If you have a HomeTown.com account, you can log in and update your information.

Links to Third-Party Websites
• Our services may contain links to, or otherwise make available, social media websites and other third-party services, websites and mobile applications that are operated and controlled by third parties. We do not take responsibility for the content, or the privacy practices employed by other websites. Unless otherwise stated, any Information you provide to any such third-party website will be collected by that party and not by HomeTown and will be subject to that party’s privacy policy (if any), rather than this Privacy Policy. In such a situation, we will have no control over, and shall not be responsible for, that party’s use of the Information you provide to them.
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Email Security
• “Phishing” is a common email scam where your email address is used to contact you and ask for personally identifiable or sensitive information. Always be cautious when opening links or attachments from unsolicited third parties. Also know that HomeTown will not send you emails asking for your credit card number, social security number or other personally identifiable information. If you are ever asked for this information, you can be confident it is not from HomeTown.

Children’s Personal Information
• We recognize the importance of protecting children’s online privacy. Our website and mobile services are intended for a general audience and are not directed to children. We do not knowingly collect personal information online from children under the age of 13.

NOTICE OF PRIVACY PRACTICES
This notice describes how health information about you may be used and disclosed and how you can get access to this information. Please review it carefully.
The healthcare providers practicing at Healthcare Clinic at select HomeTown where you receive care (your “Healthcare Clinic”) are required by law to maintain the privacy of Protected Health Information (“PHI”) and to provide you with notice of our legal duties and privacy practices with respect to PHI. References to “we,” “us,” “our” and “HomeTown” include the healthcare providers practicing at your Healthcare Clinic location and the employees and workforce members who are involved in providing and coordinating health care, as well as Walgreen Co. and the members of its affiliated covered entity. An affiliated covered entity is a group of organizations under common ownership or control who designate themselves as a single affiliated covered entity for purposes of compliance with the Health Insurance Portability and Accountability Act (“HIPAA”). The Healthcare Clinic is a member of the HomeTown affiliated covered entity and its employees, workforce members and the other members of the HomeTown’ affiliated covered entity who are involved in providing and coordinating health care are all bound to follow the terms of this Notice of Privacy Practices (“Notice”). The members of the HomeTown’ affiliated covered entity will share PHI with each other for the treatment, payment and health care operations of the affiliated covered entity and as permitted by HIPAA and this Notice. For a complete list of the members of HomeTown’ affiliated covered entity, please contact the Privacy Office.

PHI is information that may identify you and that relates to your past, present, or future physical or mental health or condition, the provision of health care products and services to you or payment for such services. This Notice describes how we may use and disclose PHI about you, as well as how you obtain access to such PHI. This Notice also describes your rights with respect to your PHI. We are required by HIPAA to provide this Notice to you.

We are required to follow the terms of this Notice or any change to it that is in effect. We reserve the right to change our practices and this Notice and to make the new Notice effective for all PHI we maintain. If we do so, the updated Notice will be posted on our website and will be available at your Healthcare Clinic, as well as at any other of our facilities and locations where you receive health care products and services from us. Upon request, we will provide any revised Notice to you.

How We May Use and Disclose Your PHI
The following categories describe different ways that we use and disclose your PHI. We have provided you with examples in certain categories; however, not every permissible use or disclosure will be listed in this Notice. Note that some types of PHI, such as HIV information, genetic information, alcohol and/or substance abuse records, and mental health records may be subject to special confidentiality protections under applicable state or federal law and we will abide by these special protections. If you would like additional information about special state law protections, you may contact the Privacy Office or visit www.HomeTownpharmacy.com.

I. Uses and Disclosures Of PHI That Do Not Require Your Prior Authorization.

Except where prohibited by federal or state laws that require special privacy protections, we may use and disclose your PHI for treatment, payment and health care operations without your prior authorization as follows:

Treatment. We may use and disclose your PHI to provide and coordinate the treatment, medications, and services you receive. For example, we may use your PHI to diagnose your health condition and may share your PHI with other Healthcare Clinic locations at select HomeTown or with your HomeTown pharmacy so that may provide you with health care services. We may disclose your PHI to other third parties, such as non-HomeTown pharmacists, doctors, nurses, technicians, and other personnel involved in your health care, or with hospitals and other health care facilities and agencies to facilitate the provision of health care services, medications, equipment and supplies you may need. This helps to coordinate your care and make sure that everyone who is involved in your care has the information that they need about you to meet your health care needs.

Payment. We may use and disclose your PHI to obtain payment for the health care products and services that we provide to you and for other payment activities related to the services that we provide. For example, we may contact your insurer, pharmacy benefit manager or other health care payor to determine whether it will pay for health care products and services you need and to determine the amount of your co-payment. We will bill you or a third-party payor for the cost of health care products and services we provide to you. The information on or accompanying the bill may include information that identifies you, as well as information about the services that were provided to you or the medications you are taking. We may also disclose your PHI to other third-party health care providers or HIPAA covered entities who may need it for their payment activities.

Health Care Operations. We may use and disclose your PHI for our health care operations. Health care operations are activities necessary for us to operate our health care business. For example, we may use your PHI to monitor the performance of the healthcare providers and staff providing treatment to you. We may use your PHI and share it with other Healthcare Clinic locations at select HomeTown as part of our efforts to continually improve the quality and effectiveness of the health care products and services we provide. We may also analyze PHI to improve the quality and efficiency of health care, for example, to assess and improve outcomes for health care conditions. We may disclose your PHI to other HIPAA covered entities that have provided services to you so that they can improve the quality and effectiveness of the health care services that they provide. We may use your PHI to create de-identified data, which is stripped of your identifiable data and no longer identifies you.

We may also use and disclose your PHI without your prior authorization for the following purposes:
Business Associates. We may contract with third parties to perform certain services for us, such as billing services, copy services or consulting services. These third-party service providers, referred to as business associates, may need to access your PHI to perform services for us. They are required by contract and law to protect your PHI and only use and disclose it as necessary to perform their services for us.

To Communicate with Individuals Involved in Your Care or Payment for Your Care. We may disclose to a family member, other relative, close personal friend or any other person you identify PHI directly relevant to that person’s involvement in your care or payment related to your care. Additionally, we may disclose PHI to your “personal representative.” If a person has the authority by law to make health care decisions for you, we will generally regard that person as your “personal representative” and treat him or her the same way we would treat you with respect to your PHI.

Food and Drug Administration (“FDA”). We may disclose to persons under the jurisdiction of the FDA, PHI relative to adverse events with respect to drugs, foods, supplements, products and product defects, or post-marketing surveillance information to enable product recalls, repairs, or replacement.
Worker’s Compensation. To the extent necessary to comply with law, we may disclose your PHI to worker’s compensation or other similar programs established by law.

Public Health. We may disclose your PHI to public health or legal authorities charged with preventing or controlling disease, injury, or disability, including the FDA. In certain circumstances, we may also report work- related illnesses and injuries to employers for workplace safety purposes.

Law Enforcement. We may disclose your PHI for law enforcement purposes as required or permitted by law – for example, in response to a subpoena or court order, in response to a request from law enforcement, and to report limited information in certain circumstances.

As Required by Law. We will disclose your PHI when required to do so by federal, state or local law.

Health Oversight Activities. We may disclose your PHI to an oversight agency for activities authorized by law. These oversight activities include audits, investigations, inspections, and credentialing, as necessary for licensure and for the government to monitor the health care system, government programs and compliance with civil rights laws.

Judicial and Administrative Proceedings. If you are involved in a lawsuit or a dispute, we may disclose your PHI in response to a court or administrative order. We may also disclose your PHI in response to a subpoena, discovery request, or other lawful process instituted by someone else involved in the dispute, but only if efforts have been made, either by the requesting party or us, to first tell you about the request or to obtain an order protecting the information requested.

Research. We may use your PHI to conduct research and we may disclose your PHI to researchers as authorized by law. For example, we may use or disclose your PHI as part of a research study when the research has been approved by an institutional review board or privacy board that has reviewed the research proposal and established protocols to ensure the privacy of your information.

Coroners, Medical Examiners and Funeral Directors. We may release your PHI to coroners or medical examiners so that they can carry out their duties. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also disclose PHI to funeral directors consistent with applicable law to enable them to carry out their duties.

Organ or Tissue Procurement Organizations. Consistent with applicable law, we may disclose your PHI to organ procurement organizations or other entities engaged in the procurement, banking, or transplantation of organs for the purpose of tissue donation and transplant.

Notification. We may use or disclose your PHI to notify or assist in notifying a family member, personal representative, or another person responsible for your care, regarding your location and general condition.

Disaster Relief. We may use and disclose your PHI to organizations for purposes of disaster relief efforts.

Fundraising. As permitted by applicable law, we may contact you to provide you with information about our fundraising programs. You have the right to “opt out” of receiving these communications and such fundraising materials will explain how you may request to opt out of future communications if you do not want us to contact you further for fundraising efforts.

Correctional Institution. If you are or become an inmate of a correctional institution, we may disclose to the institution, or its agents, PHI necessary for your health and the health and safety of other individuals.

To Avert a Serious Threat to Health or Safety. We may use and disclose your PHI when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person.

Military and Veterans. If you are a member of the armed forces, we may release PHI about you as required by military command authorities. We may also release PHI about foreign military personnel to the appropriate foreign military authority.

National Security, Intelligence Activities, and Protective Services for the President and Others. We may release PHI about you to federal officials for intelligence, counterintelligence, protection of the President, and other national security activities authorized by law.

Victims of Abuse or Neglect. We may disclose PHI about you to a government authority if we reasonably believe you are a victim of abuse or neglect. We will only disclose this type of information to the extent required by law, if you agree to the disclosure, or if the disclosure is allowed by law and we believe it is necessary to prevent serious harm to you or someone else.

II. Uses and Disclosures of PHI that Require Your Prior Authorization.
Specific Uses or Disclosures Requiring Authorization. We will obtain your written authorization for the use or disclosure of psychotherapy notes, use or disclosure of PHI for marketing, and for the sale of PHI, except in limited circumstances where applicable law allows such uses or disclosure without your authorization.

Other Uses and Disclosures. We will obtain your written authorization before using or disclosing your PHI for purposes other than those described in this Notice or otherwise permitted by law. You may revoke an authorization in writing at any time. Upon receipt of the written revocation, we will stop using or disclosing your PHI, except to the extent that we have already acted in reliance on the authorization.

Your Health Information Rights:
Obtain a paper copy of the Notice upon request. You may request a copy of our current Notice at any time. Even if you have agreed to receive the Notice electronically, you are still entitled to a paper copy. You may obtain a paper copy at the site where you obtain health care services from us or by contacting the Privacy Office.

Request a restriction on certain uses and disclosures of PHI. You have the right to request additional restrictions on our use or disclosure of your PHI by sending a written request to the Privacy Office. We are not required to agree to the restrictions, except in the case where the disclosure is to a health plan for purposes of carrying out payment or health care operations, is not otherwise required by law, and the PHI pertains solely to a health care item or service for which you, or a person on your behalf, has paid in full.

Inspect and obtain a copy of PHI. With a few exceptions, you have the right to access and obtain a copy of the PHI that we maintain about you. If we maintain an electronic health record containing your PHI, you have the right to request to obtain the PHI in an electronic format. To inspect or obtain a copy of your PHI, you must send a written request to the Privacy Office. You may ask us to send a copy of your PHI to other individuals or entities that you designate. We may deny your request to inspect and copy in certain limited circumstances. If you are denied access to your PHI, you may request that the denial be reviewed.

Request an amendment of PHI. If you feel that PHI we maintain about you is incomplete or incorrect, you may request that we amend it. To request an amendment, you must send a written request to the Privacy Office. You must include a reason that supports your request. If we deny your request for an amendment, we will provide you with a written explanation of why we denied it.

Receive an accounting of disclosures of PHI. Except for certain disclosures, you have a right to receive a list of the disclosures we have made of your PHI, in the six years prior to the date of your request, to individuals or entities other than you. To request an accounting, you must submit a request in writing to the Privacy Office. Your request must specify a time period.

Request communications of PHI by alternative means or at alternative locations. You have the right to request that we communicate with you about health matters in a certain way or at a certain location. For instance, you may request that we contact you at a different residence or post office box, or via e-mail or other electronic means. Please note if you choose to receive communications from us via e-mail or other electronic means, those may not be a secure means of communication and your PHI that may be contained in our e-mails to you will not be encrypted. This means that there is risk that your PHI in the e-mails may be intercepted and read by, or disclosed to, unauthorized third parties. To request confidential communication of your PHI, you must submit a request in writing to the Privacy Office. Your request must tell us how or where you would like to be contacted. We will accommodate all reasonable requests. However, if we are unable to contact you using the ways or locations you have requested, we may contact you using the information we have.

Notification of a Breach. You have a right to be notified following a breach of your unsecured PHI, and we will notify you in accordance with applicable law.
Where to obtain forms for submitting written requests. You may obtain forms for submitting written requests by contacting the Privacy Officer at 4171 S. Oceana Drive, New Era, MI 49446 or calling 231-861-6900. You can also visit www.HomeTownpharmacy.com to obtain these forms.

For More Information or to Report a Problem
If you have questions or would like additional information about our privacy practices, you may contact our Privacy Officer at 4171 S. Oceana Drive, New Era, MI 49446 or calling 231-861-6900. If you believe your privacy rights have been violated, you can file a complaint with the Privacy Officer or with the Secretary of Health and Human Services. You can also file a complaint through www.HomeTownPharmacy.com, and we will route your complaint to the Privacy Office. There will be no retaliation for filing a complaint.

Effective Date
This Notice is effective as of July 1, 2022.

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Privacy Policy