Centered Solutions, LLC

Privacy Policy 

Last Updated: November 3, 2026

This privacy notice describes the information we collect and process in providing our browser-based application and related services (collectively, our "Services"), including information provided by pharmacy customers, and how we use, disclose, and protect this information. It also explains the rights and choices individuals may have and how to get answers to questions about our privacy practices.

This privacy notice (Policy) describes our privacy practices when we process personal information on behalf of pharmacy customers in providing our Services. References to we, us, and our mean Centered Solutions, LLC., identified in Contact Us below. Our Terms of Use separately govern use of the Services.

Accessing or using our Services, or continuing to use them after a policy update, does not by itself constitute a choice or affirmative express consent required by the EU-U.S. Data Privacy Framework Principles, including the Supplemental Principles, described below. Where those Principles require a choice, we provide it separately before the relevant use or disclosure.

Information We Collect

We collect information using our Services as described below.

We process personal data elements such as name, phone number, address, and medication information needed for prescription ordering and local processing in our in-pharmacy workflow package. We use the data mainly to order medications and print patient labels that are affixed to specific medication containers. This data is stored on a locally hosted or private cloud server and shared with other on-site or cloud-based patient management software systems depending on site-specific needs.

Information We Receive from Third Parties

To support use of our Services, we may collect personal information from third-party partners and combine it with information collected directly or entered manually by pharmacy staff who subscribe to our Services. Such information may concern a pharmacy's patients rather than the person accessing the Services.

How We Use Information

We may use the information we collect for various purposes, including:

Legal

Subject to the Principles and their applicable exceptions, we reserve the right to access, use, preserve, transfer, or disclose any information as reasonably necessary to: (1) comply with any applicable law, regulation, subpoena, or legal process, or respond to any governmental requests or regulatory investigation and to cooperate with law enforcement, if we believe such action is required or permitted by law; (2) enforce this Policy or our Terms of Use, including investigating any potential violations; (3) protect the safety, integrity, rights, or security of our users, our Services or equipment, or any third party; or (4) detect, prevent, or otherwise address fraud, security, or technical issues related to our Services or those of our business partners. We may take such action without notice to you only where permitted by applicable law and the Principles. This provision does not independently waive the material-change notice commitments in Updates to this Policy.

Data Analysis

We may also perform data analyses (including anonymization of personal information).

Business Purposes

We may process personal information in connection with providing or improving our service, partnerships or vendor relationships, subject to the processing-purpose limitations described below in Data Integrity and Purpose Limitation. Where we act as a data processor, these activities remain subject to our customer's instructions.

Data Processor

When we process personal information provided by our customers for our Services, we act as a data processor on behalf of and on the instructions of those customers. In that relationship, our customers act as data controllers and determine the purposes and means of processing.

How We Disclose Information

We may disclose the information we collect, including in the following ways:

Affiliates Partners

We may share your information with any members of our group, which includes our affiliates, subsidiaries, and branch offices, to which it is reasonably necessary or desirable for us to disclose your information to carry out the above-mentioned information processing purposes.

Business Transfers

We may choose to buy or sell assets and may share and/or transfer your information in connection with the evaluation of and entry into such transactions. Also, if our company (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, your information could be one of the assets transferred to or acquired by a third party.

Legal/Protection

The safeguards and notice qualifications in the Legal section above also apply when we access, read, preserve, or disclose information that we reasonably believe is necessary to comply with law or court order; enforce or apply this Policy or our Terms of Use and other agreements; or protect the rights, property, or safety of Centered Solutions, our employees, our users, or others.

Aggregate Data

We may de-identify your information and process and share it in an anonymous and aggregated form for purposes in addition to those described above. For example, we may share aggregate reports about business metrics.

Transborder Transfer

We may transfer or disclose personal information to recipients in countries outside of your country, including the United States, where we are headquartered. These countries may not have the same data protection laws as the country in which data may have been provided. When we transfer or disclose your personal information to other countries, we will protect that information as described in this Privacy Notice. We have certified to the EU-U.S. Data Privacy Framework for covered transfers from the European Economic Area and to the UK Extension to the EU-U.S. DPF for covered transfers from the United Kingdom and Gibraltar. For more information, please see Centered Solutions' Data Privacy Framework Principles below.

Security

We are committed to protecting your information. We seek to use reasonable organizational, technical, and administrative measures to protect information within our organization. We also take measures to delete your personal information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it or when you request their deletion.

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of our servers has been compromised), please immediately notify us of the problem by contacting us in accordance with the Contact Us section below.

Updates to this Policy

From time to time, we may make changes to this Policy. The Last Updated date at the top of this page indicates when this Privacy Notice was last revised. If we make material changes to our privacy practices, we will provide clear and conspicuous notice describing those changes and when they take effect through the Services, email, or another appropriate communication channel before implementing them. Where we process personal information solely on a pharmacy customer's behalf, we will coordinate any required notice to affected individuals with that customer in accordance with its instructions and our obligations under the Principles. We encourage you to read this Privacy Notice periodically to stay up to date about our privacy practices and principles. Continued use of our Services after an update does not replace any separate choice or affirmative express consent required by the DPF Principles. We will provide any required opportunity to exercise choice, and obtain any required affirmative express consent, before the relevant use or disclosure.

Contact Us

If you have questions about this Policy, please contact us.

Centered Solutions, L.L.C.

175 1st Street South, Unit 2402

St. Petersburg, FL 33701

privacy@centeredsolutions.com

Data Privacy Framework Principles

Centered Solutions, LLC. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Centered Solutions, LLC. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (Principles) with regard to personal data received from the European Union and European Economic Area in reliance on the EU-U.S. DPF, and from the United Kingdom and Gibraltar in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between this privacy policy and the Principles, the Principles govern. To learn more about the DPF Program and view our certification, visit https://www.dataprivacyframework.gov/.

This Data Privacy Framework Notice supplements our Privacy Notice above. Capitalized terms not defined here have the meanings given in our Privacy Notice. References to Centered Solutions in this Notice mean Centered Solutions, LLC. References to the Principles mean the EU-U.S. Data Privacy Framework Principles, including the Supplemental Principles. Centered Solutions is subject to the investigatory and enforcement powers of the Federal Trade Commission.

References in the following sections to Personal Information received from the EEA also encompass Personal Information received from the United Kingdom and Gibraltar in reliance on the UK Extension to the EU-U.S. DPF. We apply the EU-U.S. DPF Principles to that information.

How We Obtain Personal Information

We receive, process, and host Personal Information from our pharmacy customers when providing our Services. Acting as a data processor, we process that information on behalf of and on the instructions of those customers. The processing supports medication ordering and pharmacy workflows, including correlating patient orders with information supplied directly by customers or electronically through Pharmacy Management systems and enabling customers to print and apply patient labels to medication containers. We apply the Principles to all Personal Information received in reliance on the EU-U.S. DPF or the UK Extension to the EU-U.S. DPF in connection with these activities.

Personal Information Received from the European Economic Area

We may receive from the EEA some or all of the information listed in our Privacy Notice. Some of that information may qualify as "personal information" or "personal data" (collectively, "Personal Information") as defined in the Frameworks.

Data Integrity and Purpose Limitation

We may use the Personal Information we receive from the EEA for the purposes set forth in our Privacy Notice. Any additional purpose communicated to you remains subject to the Principles, including applicable Notice and Choice requirements and, where we act as a processor, our customer's instructions. We take reasonable steps to ensure that the Personal Information we process is relevant and reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the Personal Information. We will not process Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you. We will adhere to the Principles for as long as we retain Personal Information received in reliance on the EU-U.S. DPF or its UK Extension.

We retain Personal Information in identifiable form only for as long as it serves a purpose permitted by the Principles. When it no longer serves such a purpose, we delete it or render it non-identifiable, subject to any retention permitted by the Principles. Where we process information on a customer's behalf, we apply these limits in accordance with our obligations and the customer's instructions.

When we process Personal Information on behalf of our customers, we process and retain Personal Information as necessary to provide our services to our customers, or as required or permitted under applicable law.

For Personal Information received in reliance on the DPF, the descriptions above of legal disclosures, data analysis, service improvement, vendor relationships, affiliate sharing, and business transfers remain subject to the Principles and their applicable exceptions. Those descriptions do not independently authorize incompatible processing, avoid required choices, or displace onward-transfer safeguards. Where we process information on a customer's behalf, those activities also remain subject to the customer's instructions and applicable contractual obligations.

Onward Transfers

Our Privacy Notice describes the types of third parties that we may disclose your Personal Information to, and the purposes of such disclosures. If we disclose your Personal Information to a third party acting as a data controller or as an agent, we will comply with, and protect the Personal Information as provided in, the Accountability for Onward Transfer Principle. We remain responsible for the processing of Personal Information received under the Frameworks and subsequently transferred to a third party acting as an agent if the agent processes such Personal Information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

For transfers to third-party controllers, we comply with the Notice and Choice Principles and enter into contracts requiring limited and specified purposes consistent with the individual's consent, the same level of protection as the Principles, notification if the recipient can no longer provide that protection, and cessation of processing or reasonable and appropriate remediation. For transfers to agents, we limit processing to specified purposes, ascertain that they are obligated to provide at least the same level of protection, take reasonable and appropriate steps to ensure compliant processing, require notification if they can no longer maintain that protection, and take reasonable and appropriate steps to stop and remediate unauthorized processing. We provide the Department of Commerce a summary or representative copy of relevant agent-contract privacy provisions upon request, as required by the Principles.

We may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Your Choice and Rights

To exercise a choice described in this section, contact privacy@centeredsolutions.com. We provide a clear, conspicuous, and readily available opportunity to exercise any choice required by the Principles before the relevant use or disclosure. Where we process information solely on a pharmacy customer's behalf, we coordinate with that customer in accordance with its instructions and our obligations under the Principles.

If we intend to use your Personal Information for a purpose that is materially different from the purposes listed in this policy or our Privacy Notice, or if we intend to disclose it to a third party acting as a controller not previously identified, we will offer you the opportunity to opt-out of such uses and/or disclosures where it involves non-sensitive information or opt-in where sensitive information is involved.

Medication and other health information are sensitive Personal Information under the Principles. Where required by the Principles, we obtain affirmative express consent before disclosing sensitive Personal Information to a third party or using it for a purpose other than that for which it was originally collected or subsequently authorized. Exceptions permitted by the Principles remain applicable. We also treat information identified and treated as sensitive by a transferring third party as sensitive, including information specifically identified by a UK or Gibraltar sender for that protection.

You may access your personal data, update your preferences, or ask us to remove your information from our systems as well as your associated data. You may submit a request to exercise your rights available under applicable law or express your concern about the use of your information at any time. To do so, please contact us via the email address or phone number provided below in the Contact Us section. Additionally, you may choose not to provide information to us through our Services. However, if you do not provide information, you may not be able to benefit from the Services as the information may be necessary to provide you with the Services or we may be legally required to collect it in the context of the Services. Please note that if you cease using our Services or we terminate your access to the Services in accordance with your Customer Agreement, you may no longer be able to access or update your information.

Ending use of the Services or closing an account does not extinguish rights under the Principles in Personal Information we continue to hold. Individuals may contact privacy@centeredsolutions.com to request access and correction, amendment, or deletion of information that is inaccurate or has been processed in violation of the Principles, subject to the exceptions permitted by the Principles. Where we hold information solely on behalf of a pharmacy customer, we assist that customer in responding in accordance with our obligations and its instructions.

Recourse and Enforcement

Centered Solutions' participation in EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF and to the rights of EU and UK individuals, makes Centered Solutions subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Dispute Resolution

Individuals with inquiries or complaints about our handling of Personal Information received in reliance on the EU-U.S. DPF or the UK Extension may contact privacy@centeredsolutions.com. We will respond within 45 days of receiving a complaint. If our response does not resolve the complaint, the independent recourse mechanism described below is available at no cost to the individual.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Centered Solutions commits to refer unresolved complaints concerning our handling of Personal Information received in reliance on those arrangements to VeraSafe, an alternative dispute resolution provider based in the United States, the European Union, and the United Kingdom. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed it to your satisfaction, visit https://www.verasafe.com/public-resources/dispute-resolution/submit-dispute/ for information or to file a complaint. VeraSafe's services are provided at no cost to you.

If your Data Privacy complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Data Privacy Framework ANNEX 1 at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction

Updates/Changes to Data Privacy Framework Principles

Where human resources data received in the context of the employment relationship is covered by our certification, Centered Solutions commits to cooperate with and comply with the advice of the panel established by the competent EU data protection authorities and the UK Information Commissioner's Office regarding unresolved complaints concerning that data received in reliance on the EU-U.S. DPF or its UK Extension, respectively.

Centered Solutions, LLC. verifies its DPF privacy practices through self-assessment or outside compliance review in accordance with the Principles. A statement confirming completion of that verification is signed at least annually by the appropriate authorized representative or reviewer, as required by the applicable verification method, and is made available upon request as required by the Principles. We complete annual recertification with the U.S. Department of Commerce. Failure to complete annual recertification results in removal from the relevant part of the Data Privacy Framework List and loss of eligibility to receive new Personal Information in reliance on that part of the program. We continue to apply the Principles to information previously received under the DPF for as long as we retain it. The participant list is available at https://www.dataprivacyframework.gov/s/participant-search.

Contact Us

If you have questions, concerns, or complaints about this Data Privacy Framework Notice or our privacy practices, please contact us.

Centered Solutions, L.L.C.

175 1st Street South, Unit 2402

St. Petersburg, FL 33701

privacy@centeredsolutions.com

Back to US Home Page