Last Updated: November 2023

This Privacy Notice describes the personal information that MWI Mobile and its subsidiaries (referred to as “MWI”, “we”, “us”, or “our”) collect about you, why we collect it, how we use it, and when we disclose it with third parties or service providers.

Please read this Privacy Notice carefully before you download, install, or use the MWI Mobile App and accompanying software (referred to as “MWI Mobile App” or “Application”).

Please note it is a matter entirely for your discretion whether to install or use this Application on your personal device. You provide express consent to this Privacy Notice and the terms herein by selecting “Agree” or continuing use of the MWI Mobile App. If you do not consent, then discontinue use of the MWI Mobile App.

What personal information do we collect about you?
We collect the below categories of personal information when you access the Application:

• Contact and Account Information: We collect name, email, address, and phone number, account username and password. (NOTE: This information is normally collected at the time of creating the account or resetting account access online).
• Application Activity: We collect information related to your access to and use of our Application, including the type of browser you use, access times, pages viewed, and your IP address. We may also collect this type of information in visual form when you visit our Application.
• Device Information: We collect information about the computer or mobile device you use to access our Application, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Geolocation Information: We may collect the approximate location of your device. Additionally, we may collect your precise geolocation with your permission. We use various technologies to determine location, including IP address, GPS, and other sensors which may for example provide information on nearby devices, cell towers or WiFi access points.
• Commercial Information: We collect information about your product and service preferences and interests.
• Other information you may provide to us or we infer based on the above.

How do we collect personal information?
We collect personal information directly from you in the below contexts. We also collect personal information from you using sources like advertising or marketing networks, data analytics providers, and other service providers or third parties. Collection of personal information may occur:

• If you access the Application
• In connection with your interactions, inquiries, or other requests
• If you upload or share a photo or other digital content through one of our applications, or share content linking to any of our social media
• If you participate in a contest, promotion, or survey
• If you contact us via e-mail or through our customer service, including through online chat tools we may make available
• We and our third-party vendors may use tracking tools to collect information from you. Please see “How do we use tracking technologies?” for more.

How do we use your personal information?
We may use your personal information in the following ways:

• To provide, operate, maintain, protect, and improve our Application;
• To communicate with you, respond to your inquiries, and to send you information by email, postal mail, telephone, text message, notifications, or other means about our products and services, which may include marketing notifications based on your location;
• To enhance and help us better understand your browsing experience, needs, and preferences and provide consistent, personalized services and experiences across our platforms;
• To protect the security or integrity of the Application, including to perform security analyses to verify the Application is working properly and has not been compromised based on our legitimate interests;
• To protect us, our users, and the public, and comply with applicable law, regulation, or legal process, including to validate user information for fraud and risk detection purposes, resolve disputes and protect the rights of users and third parties, respond to claims and legal process (e.g., subpoenas and court orders), fulfill our reporting obligations, monitor and enforce compliance with our contracts, including applicable Terms, and otherwise detect, prevent, or stop any activity that may be illegal, unethical, or legally actionable; and
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers is among the assets transferred.

How do we disclose your personal information?
MWI Mobile will not provide your personal information to third parties (other than MWI and Cencora) through selling, leasing, or trading, or other means, without your consent, except in the below scenarios, or to satisfy legal obligations or procedural requirements. We may disclose your personal information when necessary to fulfil the following purposes to the extent allowed by applicable laws:

• Platform providers: We engage vendors to perform certain functions on our behalf, including auditing and accounting firms, professional services consultants, providers of data hosting, storage, and analytics services, and IT and security vendors.
• Social media platforms: Where you choose to interact with us through social media, your interaction with these programs typically allows the social media company to collect information about you through cookies and other digital tracking mechanisms they place on your device. In some cases, the social media company may recognize you through these technologies even when you do not interact with their platform. Please visit the social media companies’ respective privacy policies to better understand their data collection practices and controls made available to you.
• Companies involved in advertising: We work with companies that assist us in advertising our Application to you and others who may be interested in the Application. These companies may use tracking technologies on our Application to collect or receive information over time and across different websites or platforms, including this Application and elsewhere on the internet, and use that information to provide measurement services and provide you with targeted ads.
• Corporate affiliates: We may share personal information with subsidiary companies.
• Business partners: We may work with other companies to provide you with certain product or service offerings.
• Law enforcement, government agencies, or parties in a legal proceeding: We may share personal information with these entities to comply with the law or assist law enforcement. We may also provide your personal information to third parties in the context of a subpoena or similar legal process.
• Third parties in the context of a merger or similar business transaction.

How do we use tracking technologies?
We and our third-party vendors use tracking technologies on the Application in a variety of ways to enhance or personalize your online browsing experience. These tracking technologies help us better understand your needs and preferences and tell us which parts of our Application you have visited, facilitate, and measure the effectiveness of advertisements, and provide consistent and personalized services and experiences. These tracking technologies gather information over time, some of which may be personal information as identified above in “What personal information do we collect about you.”

Third-Party Links
Third-party links on the Application may direct you to third-party applications not affiliated with us, including social media applications. We are not responsible for the content or accuracy of third-party applications, or for any other materials, products, or services of third parties.

We are not liable for any harm or damages related to the purchase or use of goods, services, resources, content, or any other transactions made in connection with any third-party websites. Please review carefully the third-party’s policies and practices and make sure you understand them before you access their website. Complaints, claims, concerns, or questions regarding third-party products should be directed to the third-party.

How do you protect my personal information?
This Application uses reasonable security measures, including but not limited to physical, technical, and organizational measures, to protect your information from unauthorized browsing, disclosure, abuse, change, destruction, and loss. We are continuously improving these security measures to protect your privacy. However, please be aware no means of transmitting data is 100% secure. Please take steps to protect your own personal information, such as by selecting a unique and complex password for your account.

Do we collect minor children’s information?
We will not knowingly request personal information from anyone under the age of 18. Our Application is not targeted to or intended for use by minor children. Accordingly, we do not have actual knowledge that we sell or share the personal information of consumers under the age of 18 years old. If we learn we received personal information from a child under the age of 18 without appropriate parental consent, we will delete the information from our database.

How long do we keep your personal information?
MWI Mobile generally retains your information for a period necessary to fulfil all purposes listed and contemplated by this Privacy Notice. Because these needs can vary for different data types in the context of different services, actual retention periods may vary. The criteria used to determine our retention periods include:

• The nature and length of time we have an ongoing relationship with you and provide the Application to you (e.g., for as long as you have an account with us);
• Whether there is a legal obligation to which we are subject (e.g., we are required to keep records of your transactions for a certain period); or
• Whether retention is advisable in light of our legal position (i.e., applicable statutes of limitations, litigation, or regulatory investigations).

Unless we are required or permitted by law to keep your personal information for a longer period of time, when this personal information is no longer necessary to carry out the purposes for which we process it, we will delete your personal information or keep it in a form that does not permit identifying you. If there is any personal information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to mitigate further use of that personal information.

What choices do I have about my personal information?
You can review and change certain personal information related to your use of the Application (such as your name and contact information) through Account Maintenance or by contacting us as described in the section entitled, “How do I contact you?” below. If you prefer not to receive promotional communications from us, such as special offers, you can let us know by contacting our customer service line. You may also follow the instructions included with the message by following unsubscribe or opt out links. Please note we may still send you messages in response to your inquiries or about other nonpromotional items, such as managing your account or relationship with us.

Do I have any rights to my personal information?
You may have rights (“Data Subject Rights”) with respect to the personal information we collect or process about you. These rights differ depending on your country or state of residency, including the European Union, the United Kingdom, California, Virginia, Colorado, Connecticut, and Utah. Please note we reserve the right to honor your Data Subject Rights to the extent required by applicable law.

• Right to Confirm Processing, Access, and/or Obtain a Copy (referred to in some countries as a Data Subject Access Request): If you ask us, we will confirm whether we are processing your personal information. Additionally, upon request, we will provide you with a copy of all personal information you are lawfully entitled to receive, potentially including specific pieces of information, along with certain other details.
• Right to Amend: If you believe your personal information is inaccurate or incomplete, you may request we correct it.
• Right to Delete: You may request we delete your personal information, but note this right is limited and subject to certain exceptions as prescribed by applicable law.
• Right of Portability: You may request we move, copy, or transfer the electronic personal information we hold about you to another organization.
• Right to Opt Out of Certain Processing Activities: You may ask us to restrict or stop the processing of your personal information. This includes general requests and requests in specific contexts, such as if we process personal information considered “sensitive” under applicable U.S. state laws or engage in certain automated decision-making activities.
• Right to Opt Out of Targeted Advertising: Targeted advertising is the practice of serving you tailored advertisements based your personal information gathered over time and across other businesses, websites, applications, or services. You have the right to opt out of this practice.
• Right to Opt Out of Sales: Some states may consider targeted advertising a “sale” of personal information. You may request we not “sell” your personal information.
• Right to Non-discrimination: We will not discriminate against you for exercising Data Subject Rights, but we may charge a reasonable fee as permitted by law in fulfilling these rights, for example if you request multiple copies of your personal information.
• Right to Appeal: If we deny your request to exercise a Data Subject Right, you may have the right to appeal the decision with us. If you would like to appeal a prior decision, please be sure to include information about your prior request so we may locate our earlier determination.
• Right to Lodge a Complaint: You may submit a complaint to the competent supervisory authority in the country in which you live if you have any concerns about our processing of your personal information.

If you or your authorized agents choose to exercise a Data Subject Right, you may do so by following the instructions in “How do I contact you?” below. Please note you may also contact Account Maintenance to access and correct your account information. To process your request to exercise a Data Subject Right, we may ask you to verify your identity by confirming your name, e-mail address, phone number, or other identifiable information we have in our records, if applicable. State specific information is available online in the State Supplement to Privacy Statement and in the Disclosures contained herein.

Additional Disclosures for California Residents
If you reside in California, please read this section for additional disclosures about how we collect, use, and disclose information about you under the California Consumer Privacy Act (or “CCPA”) (California Civil Code Section 1798.100 et seq.).

• Categories of Personal Information Collected: In the preceding 12 months, we may have collected the personal information listed in the section “What personal information do we collect about you?” above. This information falls into the following categories under the CCPA: identifiers; categories of personal information described in Cal. Civ. Code 1798.80(e); commercial information; geolocation information; audio, electronic, or visual information; internet or electronic network activity information; inferences drawn from the above categories. Additionally, we collect the following “sensitive” personal information: precise geolocation, account credentials, and contents of messages you send to our customer service providers.
• Sensitive Personal Information Uses or Disclosures: We do not use or disclose “sensitive” personal information for purposes other than those specified by the CCPA.
• Business or Commercial Purpose for Collecting and Selling Information: We collect personal information for the business and commercial purposes described in “What personal information do we collect about you?” and “How do we use your personal information?” above.
• Categories of Sources of Personal Information: We collect personal information from and about you as described in “How do we collect personal information about you?” above.
• Categories of Third Parties with Whom We Disclose Information: We may disclose your personal information with third parties as described in “How do we disclose your personal information?” above.
• Categories of Personal Information Disclosed: In the preceding 12 months, we have disclosed the categories of personal information listed in “What personal information do we collect about you?” for the reasons described in “How do we disclose your personal information?” above.
• Sale or Share of Personal Information: We engage in the practice of cross context behavioral advertising, also known as online targeted advertising, we may “sell” and/or “share” your personal information as those terms are defined by the CCPA. In the preceding 12 months, we may have “sold” or “shared” identifiers, commercial information, and internet or electronic network activity information with data analytics, advertising networks, and/or social media networks.

Your Nevada Rights
2019 Nev. L. 211 permits customers of MWI who are Nevada residents to request we not sell their personal information. We do not sell personal information as defined by Nevada law. If you are a resident of Nevada and choose to request we not sell your information in the future, please contact us following the instructions below.

Information for Residents of European Economic Area or United Kingdom
For personal information subject to the General Data Protection Regulation (“GDPR”), we will not collect or process the information unless we have a lawful basis to do so under GDPR. The principal lawful bases we rely on include:

• Legitimate interests: We process your personal information in connection with meeting our legitimate business objectives (as listed above) or those of a third party. We balance those interests against any risks to your rights from our data processing activities and do not pursue any data processing where the potential harm to your rights outweighs our legitimate interests.
• Performance of a contract: We process personal information to the extent necessary to perform our obligations under a contract with you or your organization, or if requested by you or your organization to contract with us.
• Legal obligation: We may need to process personal information to comply with a law or legal process to which we are subject.
• Consent: If we rely on consent as a lawful basis for processing your personal information, we will obtain your consent before processing your personal information for one or more specific purposes. You are free to withdraw consent at any time.

Cross Border Transfers
MWI is headquartered in the United States and uses service providers around the world. Information collected by this Application may be stored on and processed by resources and computer servers located in the United States and other countries where MWI and Cencora have offices or conduct business.

As part of our data processing activities, we may transfer your personal information across borders, including into countries whose laws protecting personal information may not be as robust as your home country’s laws. We endeavor to take reasonable steps to have adequate safeguards in place to protect your personal information when it is transferred across borders.

If we transfer any personal information from the European Economic Area to countries not deemed by the European Commission to have an adequate level of personal information protection, we will attempt to use adequate safeguards or other lawful means to make the transfer in accordance with applicable privacy laws.

Updates to this Privacy Notice
This Application will modify or update its Privacy Notice from time to time. In this case, we will provide notice and adopt feasible channels and means to notify you of the updates. You are welcome to access this Privacy Notice for the latest changes. Your use of the Application following any such updates will constitute your acceptance of updates.

How do I contact the MWI?
For questions about our Privacy Notice, to make choices about receiving promotional communications, to request to exercise a Data Subject Right, or to update your personal information, you can contact us by email, at privacy@cencora.com, or by writing us at:

Cencora, Inc.
Corporate Headquarters
1 West First Avenue
Conshohocken, PA 19428
Phone: 1-800-829-3132
Attention: Amy Huffman, Vice President, Global Privacy Operations