Last revised September 11, 2026.

Rise Healthcare Tech, Inc., doing business as both “Ostro” and “RxDefine”, and our affiliates (collectively, “Veeva Ostro”) are committed to maintaining a privacy program that is designed around trust, transparency and respecting your rights in your personal information. This privacy notice describes how we process personal information, including what information we collect, why we collect it, how we use it, how we may share it, and your controls over your personal information.

Scope

This privacy notice applies to personal information collected through our websites ostro.veeva.com and kinara.co and our promotional communications—including e-mail, text message, and related online or offline marketing channels (collectively, the “Veeva Ostro Marketing Tools”).

For information about how Veeva Ostro processes personal information in its delivery of products and services, refer to our Processor Privacy Notice. For information on Veeva’s other privacy practices, including as part of veeva.com (a separate website) and Veeva-sponsored events, please refer to our notice at veeva.com/privacy.

Information We Collect

We may collect the following types of information through the Veeva Ostro Marketing Tools:

• Device & Usage: We collect device and usage information such as cookie records, browser type, internet service provider (ISP), device IP address, operating systems and versions, device motion data, web beacons and clickstream data.
• Interactions: When you engage with our Veeva Ostro Marketing Tools, including by responding to surveys, subscribing to publications, attending events, or engaging in any similar activities through Veeva Ostro Marketing Tools, we collect information that you provide through that process, such as your name, email address, phone number, job title, professional information, information about the products or services of interest to you, and other similar information.

How We Collect Information

We collect your information directly and indirectly (by observing your actions on our websites or from your devices) as you engage with the Veeva Ostro Marketing Tools. This includes collecting information using analytic tools and other tracking technologies. Please see our Cookie Notice for more information.

Why We Collect Information and How We Use It

We collect your information to help us understand how you interact with us, to provide you with relevant information and services, and to help us ensure the Veeva Ostro Marketing Tools are working as designed. This includes processing personal information as necessary to analyze, improve and optimize the delivery and use of the Veeva Ostro Marketing Tools and their security.

We do not make decisions about you which have legal or similarly significant effects on you, based solely on the automated processing, including profiling, of your information.

Sharing Your Information

We may share personal information internally and with our subsidiaries and other third parties, for the following purposes:

• to support the purposes described in the section above entitled “Why We Collect Information and How We Use It”;
• to enable third parties to provide services on our behalf;
• to comply with applicable law, legal obligations and valid legal processes such as search warrants, subpoenas, and court orders;
• as necessary to establish, exercise or defend against potential, threatened or actual litigation;
• when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate or prevent fraud or other illegal activity;
• in connection with a merger, sale or asset transfer; and
• for additional purposes with your consent, where consent is required by applicable law.

When we share your personal information, we will take reasonable steps to ensure that we only share the minimum personal information necessary for the specific purpose and circumstance.

Cookie Notice

Scope

We use information-gathering tools, such as cookies, pixels, tags and web beacons, to collect information about you as you engage with the Veeva Ostro Marketing Tools. These technologies are used in analyzing trends, administering our websites, tracking your interactions with the Veeva Ostro Marketing Tools.

Cookies

The Veeva Ostro Marketing Tools may ask your browser to store small text files called “cookies” on your device. Cookies are used to collect information about you, your preferences, or your device. The cookies that are set by us are called first-party cookies. We mostly use cookies to collect information to make the Veeva Ostro Marketing Tools work as you expect them to, to analyze usage of the Veeva Ostro Marketing Tools and to provide a more personalized experience.

Some cookies may be stored that are not controlled by us; these are called third-party cookies. You should review the privacy and cookie policies of these services to find out how these third parties use cookies.

We classify cookies into the following categories:

• Strictly Necessary. These cookies are necessary for the Veeva Ostro Marketing Tools to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences or filling in forms. You can set your browser to block or alert you about these cookies, but if you do, some parts of the site will not work. These cookies do not store any personally identifiable information.
• Performance. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the website. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
• Functional. These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then these services or features may not function properly.
• Targeting. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

You can choose not to allow certain types of cookies by visiting our Cookie Preferences Center, which can be accessed within the global footer of the Veeva Ostro websites.

You can delete all cookies that are stored on your computer, and you can set most browsers to prevent them from being placed. Please note that your choices may be specific to Veeva Ostro website you are navigating and to the device and browser you are using, and that removing or blocking non-required cookies can negatively impact your user experience and may cause some of the services and features to work incorrectly or no longer be available.

For more information about how cookies work, see aboutcookies.org.

Web Beacons and Similar Technologies

We use web beacons and similar technologies to understand how you interact with the Veeva Ostro Marketing Tools. Web beacons are clear electronic images that help us understand what content you have accessed. Web beacons do not place information on your device, but they may work in conjunction with cookies to monitor website activity. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. We use web beacons to operate and improve the Veeva Ostro Marketing Tools and our promotional communications.

Global Privacy Controls

Global Privacy Controls are mechanisms that allow you to opt out of the sale of your personal information or the use of your personal information for cross-context targeted advertising purposes. If you turn on a Global Privacy Control setting and we detect an opt out preference signal, we will honor that preference.

Retaining Your Information

We only keep your information for as long as it is necessary and relevant for the purposes described in this privacy notice. We retain device and usage information for up to one year (or as otherwise required by law).

Your Controls

We offer you certain controls over your information. These controls may include the right to access, delete, correct, transfer and opt-out or object to the processing of your information. If you choose to exercise your rights, we will respond to your request in accordance with applicable laws, which may vary depending on where you live.

If you wish to exercise your privacy rights, please email ostroprivacy@veeva.com or call us (free of charge) at 1 (877) 807-3230. In order to process your request, we require certain information about you. We will only use this information to verify your identity and facilitate the processing of your request. You may use an authorized agent to submit a request on your behalf. Authorized agents must provide appropriate documentation of their authorization (e.g., power of attorney).

There may be times when we are unable to fulfill your request; in those cases, we will let you know why we are unable to fulfill your request. If we deny or are otherwise unable to fulfill your request, you may have the right to appeal. To submit an appeal, contact us at ostroprivacy@veeva.com.

To unsubscribe from Veeva promotional emails, click on the “unsubscribe” link located on the bottom of the email. Please note that customers cannot opt out of receiving transactional emails related to the use of Veeva Ostro’s products and services.

Children’s Privacy

The Veeva Ostro Marketing Tools are not designed for or directed at children, and we do not knowingly collect personal information from children under the age of 18. If you believe we may have mistakenly collected the personal information of a minor without appropriate consent, please contact us at ostroprivacy@veeva.com and we will investigate and promptly address the issue.

Security

We maintain a privacy and security program with technical, physical and organizational safeguards designed to protect against the wrongful access, use or disclosure of personal information, and to provide a level of security which we believe is appropriate to the risk our processing of your personal information poses to your privacy. We regularly review and modify our security measures to reflect changing technology, laws and regulations, risk, industry and security practices and other business needs.

Transfer of Personal Information Between Countries

We are a global company. As a global company, we may transfer your personal information to various locations around the world for the purposes described in this privacy notice. We apply the protections and limitations described in this privacy notice regardless of where we process your personal information. We also comply with various legal frameworks that enable the cross-border transfer of personal information.

Where required, we rely on transfer mechanisms that lawfully support data transfer to locations that are not considered “adequate” by the appropriate data protection authority, which may include standard contractual clauses, obtaining your consent or another recognized transfer mechanism.

Contact Us

If you wish to exercise your privacy rights, please email ostroprivacy@veeva.com. If you have any questions about our privacy practices, you can contact our Chief Privacy Officer at:

Veeva Systems Inc.
4280 Hacienda Drive
Pleasanton, CA 94588 USA
privacy@veeva.com

Changes to this Privacy Notice

From time to time, we may change this privacy notice to reflect changing technology, laws, regulations, risk, industry and security practices and other business needs. The most recent version will be found on the Veeva Ostro websites; we post its effective date at the top. If we make a material update, we may notify you by posting notice on the Veeva Ostro websites or by other means, consistent with applicable law.

Residents of the EU, UK, and Switzerland

Rise Healthcare Tech, Inc. is the data controller for the Veeva Ostro Marketing Tools. Generally, the legal basis for processing your personal information is our legitimate interest in providing the Veeva Ostro Marketing Tools. The legal basis for processing certain interaction data (e.g., information you provide to subscribe to our promotional communications) is your consent.

Residents of California

Refer to the section of this privacy notice entitled “Your Controls” for information on how to exercise your rights.

The categories of personal information we collect include:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
• Personal Information categories as defined in the California Customer Records statute, Cal. Civ. Code Section 1798.80, such as name, education, employment, employment history and financial information.
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.
• Geolocation data, such as locations determined by an IP address or other technical measures.
• Professional or employment-related information, such as job title as well as work history and experience.

We collect this information to support the purposes described in the section of this privacy notice entitled “Why We Collect Information and How We Use It”. We collect your personal information from the sources described under the “How We Collect Information” section of this privacy notice.

We disclose the information from the above listed categories for the purposes and to the categories of recipients described in the section of this privacy notice entitled “Sharing Your Information”. We do not use or disclose sensitive personal information for any purpose other than those specified in Section 7027(m) of the CCPA regulations.