PRIVACY POLICY

Effective Date: December 19, 2024

Who We Are and What We Do

At FLYWHEELRX.COM (“we,” “us,” or “our”), we connect experienced health care consultants with health care-related companies (“you” or “user”) for medical or health care-related projects. Think of us as a professional network platform where consulting opportunities and expertise meet.

The Information We Collect About Our Users

Registration 

When you register on our Site and create a user profile, you choose to share and consent to our use of the following personal information:

  • Contact Details: Your name, email address, mailing address, and phone number.

  • Professional Information: Your education, credentials, areas of expertise, licenses, certifications, work history, resumes, and/or CVs.

  • Company Information: Company name, industry, and contact information.

  • Account Information: Username, password, and any preferences you set within your user profile or account.

  • Communication Content: Messages or feedback you send us.

  • Interest categories: Self-declared professional interests aligning expertise with industry opportunities.

  • Inferences: Inferences drawn from the above categories of information used to create user profiles reflecting preferences or behavior.

Posting an Opportunity

Company Users will have the option to post an Opportunity which will include the scope of the Company’s project and scope of consultant engagement offered. When you post an Opportunity, you choose to share and consent to our use of the opportunity information.

Information Collected Automatically

We collect data whenever our Site FLYWHEELRX.COM (“Site”) is accessed:

  • Technical Data: IP address, browser type, operating system, and device information.

  • Location Data: General geographic area derived from IP address or GPS (as applicable).

  • Usage Data: Pages you visit, links you click, your search history, and the time you spend on our Site, as well as your interactions with our website, applications, or advertisements.

  • CAPTCHA Data: Your IP address, browser type, and interaction data to verify that you are a human user and not an automated system.

How We Use Your Information

We use your information for our legitimate interests listed below. These interests are balanced against your rights and interests to ensure your data is handled responsibly

  • Facilitating Connections: We use your information to connect Consultants and Companies and to match Consultants to Opportunities.

  • Improving Our Platform: We analyze user usage patterns to enhance user experience and introduce new features.

  • Communications: We use your information to send you updates, newsletters, and important notices about your account or our platform.

  • Marketing: We may occasionally send you marketing information about our platform or other services that might interest you. You can opt out of these communications at any time.  Email info@flywheelrx.com to opt out.

  • Subscription Management: We use your information to manage your subscription and process payments through our secure payment processors: Stripe and SquarePayments.  Our payment processors, such as Stripe and SquarePayments, act as data processors on our behalf. They are contractually obligated to comply with GDPR requirements.

  • Security and Fraud Prevention: We use your information to protect our users against fraud and unauthorized access.

  • Third Party Services.  We may sell your personal information to third parties for various business purposes, including but not limited to marketing, analytics, and service improvement. You have the right to opt out of the sale of your personal information by requesting that we DO NOT SELL MY PERSONAL INFORMATION.  You can email your request to info@flywheelrx.com. 

We do not use your personal data to market third-party services beyond the scope of these sales, and we do not sell your data to third parties for unrelated commercial purposes.

Sharing Your Information

Your information may be shared under the following circumstances:

  • Third-Party Service Providers: Your information is shared to the extent necessary for our third-party service providers to provide us with email delivery, website hosting, and payment processing. These providers include:

    • Stripe

    • Squarespace

    • SquarePayments

    • Zoom

      Under the GDPR/CCPA, these partners may be considered “processors” or “service providers” rather than “third parties.” They will only process data in accordance with our instructions and applicable law.

  • Other Users: The information you share on the Site and Platform may be seen by other users to facilitate professional connections.

  • Data Analytics and Advertising Partners: We work with partners to help us analyze how users interact with our website and to market our services effectively. Some of these partners may receive limited Personal Data in order to provide advertising solutions, measure ad performance, or develop user profiles for personalized advertising.

  • Marketing and Lead Generation: We may sell contact information or user preferences (where permitted) to third parties interested in offering related services or products.

  • Corporate Transactions: In the event of a merger, acquisition, or any form of sale of some or all of our assets, the Personal Data we hold may be transferred as part of that transaction, subject to confidentiality agreements and applicable law.

You have the right to withdraw consent or object to our processing activities at any time. If you do so, we will promptly cease processing your personal data. We will not share your personal data with third parties for their marketing purposes when you request that we do not so.  outYou can email info@flywheelrx.com at any time to exercise your rights.  You can also click below to request that your data not be shared with third parties for their marketing purposes.

Your Rights and Choices

We believe in transparency and giving you control over your information. You can delete your Registration at any time. Please note that cached versions of your user profile may still exist.

For Users Worldwide:

  • Access: You can request details about the personal data we hold about you.

  • Correction: If any information is inaccurate or incomplete, you can change it in your account settings.  Or you can let us know—we'll fix it.

  • Deletion: You may ask us to delete your personal data and we will delete your Registration and User Content.  Any current Subscription Services will be terminated.

  • Restriction: You can request that we limit how we use your data by opting out of the sale of your personal information or that we refrain from contacting you for marketing purposes by emailing info@flywheelrx.com

  • Portability: We can provide your data in a structured, commonly used format.

  • Objection: You have the right to object to certain types of processing.

  • Withdraw Consent: If we process your personal data based on consent, you can withdraw it at any time at by requesting that we delete your Registration.

For California Residents (CCPA Rights):

  • Right to Know: Ask us what personal information we collect, use, and share.

  • Right to Delete: Request that we delete personal information we've collected from you.

  • Right to Opt-Out: You have the right to opt out of the sale of your personal information.

  • Right to Non-Discrimination: We won't treat you differently for exercising your rights.

To exercise any of these rights, please contact us at info@flywheelrx.com.

Cookies and Other Technologies

Our Site uses cookies to enhance your experience. Cookies help us:

  • Personalize Your Experience: Remember your preferences and settings.

  • Understand Usage: Analyze how you use our Site so we can improve it.

  • Deliver Relevant Content: Show you matching postings and relevant content.

Cookie Consent: If you are in the EU, you will see a cookie consent banner. We will only use non-essential cookies with your explicit consent. If you choose not to accept certain cookies, some features of our Site may not function properly.

You can adjust your browser settings to manage cookies or to alert you when websites set or access cookies. For more detailed information about the cookies we use and the purposes for which we use them, please see our Terms of Use.

CAPTCHA Disclosure

To protect our Site from spam and abuse, we use CAPTCHA services (such as Google reCAPTCHA). CAPTCHA helps verify that you are a human user and not an automated system. Here’s how CAPTCHA works and what information it collects:

  • Information Collected: CAPTCHA services may collect technical information such as your IP address, browser type, operating system, and interaction data (e.g., mouse movements, keystrokes).

  • Purpose: The primary purpose of using CAPTCHA is to prevent automated bots from abusing our Site, ensuring that interactions are conducted by real users.

  • Third-Party Processors: CAPTCHA services may be provided by third-party companies (e.g., Google). These third parties have their own privacy policies governing the use of the collected data.

  • Data Sharing: The information collected through CAPTCHA is used solely for verifying user authenticity and is not shared with other third parties for marketing or unrelated purposes.

  • Your Choices: By using our Site, you consent to the data collection practices of the CAPTCHA service provider. If you do not agree to the use of CAPTCHA, you may not be able to access certain features of our Site.

For more information about how CAPTCHA services handle your data, please refer to the privacy policies of the respective CAPTCHA providers, such as Google Privacy Policy.

Keeping Your Information Secure

We take your security seriously and implement appropriate technical and organizational measures to protect your personal information from unauthorized access, use, or disclosure. While we strive to protect your data, please remember that no method of transmission over the Internet is completely secure.

International Data Transfers

Our Site is operated in the United States, and your personal information may be transferred to and processed in countries other than where you are located. We utilize Standard Contractual Clauses approved by the European Commission to ensure that your data is protected when transferred outside the EU and have entered into Data Processing Agreements with all our third-party service providers to ensure adherence to GDPR standards for data protection.

By using our services, you consent to the transfer of your personal information to the United States and other countries where we operate.

Data Retention

We retain your personal data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When we no longer need your information, we will dispose of it securely.

Third-Party Links and Services

Our Site may contain links to third-party websites or services. These sites have their own privacy practices, and we encourage you to review their privacy policies to understand how they handle your information.

Private Health Information

We do not collect private health information.  Our Site is not a medical provider or health care provider.  You should not use our Site for medical or health care advice.  Our Site is not intended to be used to transmit or store private health information.  Private health information means identifying information about an individual relating to their physical or mental health (including medical history), the providing of health care to the individual, payments or eligibility for health care, organ and tissue donation and health plan or insurance number.

Children’s Privacy

Our services are designed for adults. We do not knowingly collect information from anyone under 18 years old. If you believe we might have information from or about a minor, please contact us immediately at INFO@FLYWHEELRX.COM, and we will take appropriate action.

Changes to This Privacy Policy

From time to time, we may update this Privacy Policy to reflect changes in our practices or for operational, legal, or regulatory reasons. We will notify you of any significant changes by posting the new policy here and updating the "Effective Date" above.  We will also require all Registered Users to annually accept our Terms of Use and Privacy Policy.  

Let’s Stay in Touch

Got questions or comments about this Privacy Policy? Contact us:

  • Email: INFO@FLYWHEELRX.COM

  • Mailing Address: 
    FlywheelRX Group LLC 
    3626 Fair Oaks Blvd., Suite 100
    Sacramento CA 95864

  • Data Protection Officer (DPO):

  • Name: Jordan Newmark

  • Email: info@flywheelrx.com

Accessibility Matters

We care about our users and want everyone to have access to our policies. If you need this Privacy Policy in a different format, please contact us at FLYWHEELRX.COM, and we'll be happy to assist.

Legal Basis for Processing

We process your personal data based on the following legal grounds:

  • Consent: When you have given us explicit consent to process your data for the specific purpose of your Registration and use and engagement with our Site and Platform.

  • Performance of a Contract: To provide you with our services as outlined in our Terms of Use.

  • Legal Obligation: To comply with legal and regulatory requirements.

  • Legitimate Interests: For our legitimate business interests, such as improving our services, provided that those interests are not overridden by your rights and interests.

California "Shine the Light" Law

California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding our disclosure of personal information in the past calendar year to third parties for their direct marketing purposes. You may send us requests for this information to info@flywheelrx.com. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Do Not Track Signals

Our Site does not respond to Do Not Track (DNT) signals. Currently, there is no universally accepted standard for DNT signals, and we await the development of such standards.  However, we respect user preferences and offer options to control data collection through your account settings and opt out preferences as detailed in this Privacy Policy.

Data Breach Notification

In the unlikely event of a data breach, we will notify affected users and relevant supervisory authorities within the timeframes required by applicable laws, including GDPR and U.S. state laws.

For our California users, in the event of a data breach, we will notify affected users and the California Attorney General within 72 hours of discovering the breach or as otherwise required by applicable law.