Privacy Policy

1. Introduction

Rising Pharma Holdings, Inc., doing business as Rising Pharmaceuticals (“Rising,” “we,” “us,” or “our”), operates the website edetaterising.com (the “Website”) to facilitate ordering of Edetate Calcium Disodium Injection, USP through Rising’s authorized specialty distribution channels. This Privacy Policy describes what information we collect, how we use and share it, and your rights regarding that information. The Website is operated in the United States and is intended solely for licensed U.S.-based healthcare institutions, pharmacies, and other authorized entities—not individual patients or consumers.

2. Who This Policy Applies To

This Privacy Policy applies to all individuals who access or use this Website, including: (i) authorized representatives of licensed pharmacies, hospitals, outpatient infusion centers, and other healthcare institutions; (ii) individuals who submit inquiries, register for an account, or place orders through the Website; (iii) individuals who contact Rising by phone or email in connection with the Website or the Product; and (iv) any other person who provides information to Rising in connection with this Website. By using this Website, you acknowledge that you have read and understood this Privacy Policy and consent to the practices described herein.

3. Information We Collect

We collect information about you in three main ways: directly from you, automatically through your use of the Website, and from third parties.

3.1 Information You Provide Directly. When you use this Website—whether to create an account, place an order, submit an inquiry, or report an adverse event—you may provide us with:

• Business and Account Information: Entity name, type of facility, business address, business telephone number, and business email address.
• Professional Credentialing Information: DEA registration number, pharmacy license number, hospital or institutional license number, NPI number, and any other professional credentials or regulatory authorizations necessary to verify your eligibility to purchase prescription pharmaceutical products.
• Order and Transaction Information: Product selections, quantities, shipping and delivery addresses, billing information, and purchase history.
• Payment Information: Payment card details or other payment information, which is processed through our third-party payment processor(s) and is not stored by Rising on its own systems.
• Communications: Messages, questions, feedback, complaints, or adverse event reports that you submit through the Website or send directly to Rising by email or telephone.

3.2 Information Collected Automatically. When you visit this Website, certain technical information is collected automatically through cookies, web beacons, server logs, and similar tracking technologies, including:

• Your IP address and approximate geographic location;
• Browser type, version, and language settings;
• Device type and operating system;
• Pages visited, time spent on each page, and navigation paths through the Website;
• The URL of the page that referred you to this Website; and
• Date and time of your visit.

This information is used for Website security, analytics, and improving the user experience. See Section 7 for details.

3.3 Information from Third Parties. We may receive information about you from authorized third parties in connection with order processing, eligibility verification, and regulatory compliance, including our specialty distribution partner(s) (e.g., IPD Pharma), logistics and shipping providers, payment processors, and regulatory authorities such as state boards of pharmacy and the DEA.

4. How We Use Your Information

We use the information we collect for the following purposes:

4.1 Order Processing and Account Management. We use your business and credentialing information to verify that you are authorized to purchase prescription pharmaceutical products, to process and fulfill orders, to arrange for shipping, and to manage your ongoing account relationship with Rising.

4.2 Regulatory and Legal Compliance. Rising is legally required to maintain accurate records related to the sale, distribution, and traceability of prescription pharmaceutical products. We use your information to comply with:

• The Drug Supply Chain Security Act (DSCSA) — including the maintenance of transaction information, transaction history, and transaction statements;
• Drug Enforcement Administration (DEA) recordkeeping requirements;
• FDA reporting and pharmacovigilance obligations, including adverse event reporting requirements;
• State pharmacy board recordkeeping and reporting requirements; and
• Any other applicable federal or state regulatory obligation.

4.3 Adverse Event Reporting. If you report a suspected adverse reaction associated with this Product, we are required by federal law to report certain information to the FDA. We may use your contact information and clinical details for follow-up. All adverse event information is handled with appropriate care and confidentiality.

4.4 Communications. We use your contact information to respond to inquiries, send order confirmations and shipping updates, communicate product safety or recall notices, and notify you of material changes to this Policy or the Prescribing Information.

4.5 Website Operations and Security. We use automatically collected information to monitor Website security, detect and prevent fraud or unauthorized access, diagnose technical issues, and improve Website functionality.

4.6 Legal Rights and Enforcement. We may use your information to enforce our Terms and Conditions of Sale, protect Rising’s legal rights, prevent or respond to fraud, and comply with lawful government or court requests. We do not use information collected through this Website for unsolicited marketing without your consent.

5. How We Share Your Information

We do not sell your personal information or your organization’s business information to third parties. We may share your information with third parties only in the following circumstances:

5.1 Service Providers. We engage third-party vendors for Website hosting, payment processing, order fulfillment, shipping, customer support, and analytics. These vendors access your information only as necessary to perform services on our behalf and are contractually required to maintain appropriate data security standards.

5.2 Specialty Distribution Partners. We share relevant order and credentialing information with our authorized specialty distribution partner(s)—such as IPD Pharma—for the purposes of processing, fulfilling, and delivering orders placed through this Website.

5.3 Regulatory and Government Authorities. We will disclose your information to regulatory agencies, law enforcement, or other governmental bodies when required by applicable law, regulation, legal process, or government request—including DSCSA reporting, DEA recordkeeping, FDA adverse event submissions, and state pharmacy board requirements. We will endeavor to notify you of any compelled disclosure to the extent permitted by law.

5.4 Legal Proceedings and Protection of Rights. We may disclose your information to courts, attorneys, or other parties as necessary to establish, exercise, or defend legal rights, enforce our Terms and Conditions of Sale, or comply with a valid legal obligation.

5.5 Business Transfers. . If Rising is involved in a merger, acquisition, sale of substantially all of its assets, or similar corporate transaction, your information may be transferred to the successor entity, subject to applicable legal requirements. We will take reasonable steps to ensure continued protection of your information consistent with this Privacy Policy.

6. HIPAA and Patient Information

Because this Website is designed for B2B transactions with licensed pharmaceutical purchasers, Rising does not typically function as a covered entity or business associate under HIPAA in connection with transactions on this Website. However, certain information submitted—particularly in connection with adverse event reporting—may relate to individual patients. We handle all such information with appropriate discretion, use it only for the purpose for which it was submitted, and disclose it only as required by applicable law. Nothing in this Privacy Policy modifies or limits any HIPAA obligations that apply to the Purchaser. Purchasers are solely responsible for their own HIPAA compliance, including obtaining any necessary patient authorizations before sharing PHI with Rising.

7. Cookies and Tracking Technologies

This Website uses cookies and similar tracking technologies to support functionality, enhance your experience, and analyze performance. The categories of cookies we use are:

7.1 Essential Cookies. These cookies are necessary for the Website to function properly. They enable basic features such as maintaining your session, remembering items in your order, and ensuring secure access to account areas. Essential cookies cannot be disabled without impairing Website functionality.

7.2 Analytics Cookies. We use analytics tools (e.g., Google Analytics) to understand how visitors interact with the Website. These tools may collect browsing activity in aggregate, anonymized form. You may opt out by adjusting your browser settings or using the analytics provider’s opt-out mechanism.

7.3 No Advertising Cookies. . We do not place or permit third-party advertising networks to place behavioral advertising cookies on this Website. This Website does not serve targeted or retargeted advertising.

7.4 Managing Cookies. . You can control cookie settings through your browser. Note that disabling certain cookies may affect Website functionality or prevent you from completing an order.

8. Data Retention & Data Security

We retain information collected through this Website for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with our legal, regulatory, and operational obligations. Rising maintains administrative, technical, and physical safeguards to protect information from unauthorized access, use, disclosure, alteration, or destruction. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security. If you believe your interaction with us is no longer secure, please contact us using the information in Section 13. To submit a privacy rights request, contact us by: email: legalnotices@risingpharma.com (with “Privacy Rights Request” in the subject line) or by mail: Rising Pharma Holdings, Inc., Attn: Legal, 2 Tower Center Blvd., Suite 1401A, East Brunswick, NJ 08816. We will respond to verifiable requests within the timeframes required by applicable law. If we cannot fulfill a request due to legal retention obligations or other lawful exceptions, we will explain the basis for any partial denial.

9. Links to Third-Party Websites

This Website may contain links to third-party websites (e.g., ipdpharma.com, DailyMed, FDA MedWatch). These links are provided for convenience only. Rising assumes no responsibility for the content or privacy practices of any third-party website, and your use of those sites is subject to their own privacy policies.

10. Links to Third-Party Websites

This Website may contain links to third-party websites (e.g., ipdpharma.com, DailyMed, FDA MedWatch). These links are provided for convenience only. Rising assumes no responsibility for the content or privacy practices of any third-party website, and your use of those sites is subject to their own privacy policies.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the Effective Date and post the revised version on this Website; for significant changes, we may also notify you by email or prominent Website notice. Your continued use of the Website after a revised Policy is posted constitutes acceptance of the revised terms.

12. How to Contact Us

For questions about this Privacy Policy, our information practices, or to submit a privacy rights request, contact us at:

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