Empower Applicant Privacy Policy

This Empower Applicant Privacy Policy (“Policy”) is applicable to Empower Clinic Services, L.L.C. d/b/a Empower Pharmacy (“Empower”) U.S. applicants only (“applicant” or “you”).

This Policy describes how Empower collects, uses, and processes Personal Information that you provide to Empower as part of our applicant process. Empower also collects and processes additional types of Personal Information about you throughout your employment with Empower to administer human resources programs and to comply with employment terms and conditions and applicable law, social security, and workplace health and safety obligations. You may contact Empower’s Privacy Officer by emailing privacy-officer@empowerpharmacy.com.

This Policy was last updated March 31, 2026.

For the purpose of this Policy, “Personal Information” means (i) information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with a particular identified or identifiable individual, device, or household; and (ii) information defined as “Personal Information,” “Personal Data,” “Personally Identifiable Information” or a similar term under applicable law. Information that has been de-identified pursuant to applicable law or anonymized by Empower or others is no longer personal information and is not covered by the terms of this Privacy Policy.

Protected health information maintained by Empower, may also be subject to the Health Insurance Portability and Accountability Act (“HIPAA”).

Revisions to the Policy

Empower reserves the right and may revise this Policy as features are added or modified, modifications to information management are made, or as laws change that may impact the Empower application process. If we materially change the way in which we process your personal data, we will provide you with prior notice or request your consent prior to implementing such changes if required by law. We strongly encourage you to carefully read the privacy statement of any website you visit.

Collecting, Using, and Disclosing Personal Information

Empower collects your personal data to take employment application steps at your request, to comply with legal obligations and to pursue legitimate interests of Empower. To the extent permitted by applicable law, Empower collects the following personal data from you in connection with your job application:

1. Information We Collect

We collect the following personal information from you in connection with your application process:

Information from your interaction with Empower’s website during the application process. For more information, please visit Empower’s Privacy Policy linked here.
Identifiers from the application and recruitment process, including but not limited to:
- Name;
- Mailing address;
- Email address;
- Telephone number;
- Background check information (where permitted by law and typically post-conditional offer);
- Facial photographs or video;
- Resume and/or Curriculum Vitae (CV);
- Work experience;
- Education history;
- Location;
- Right to work information;
- Licensure number (if applicable);
- Willingness to relocate (if applicable);
- Willingness to execute a restrictive covenant (if applicable);
- Name and contact details of provided references;
- Information related to how you heard about the job;
- Why you left your previous employer;
- Information regarding your availability;
- Interview data; and
- Any other information or files you elect to share regarding your qualifications or application.

Information collection may occur through recording during phone calls or interviews with Empower personnel. Personal Information does not include publicly available information. Your decision to apply for an Empower position and share your personal data to Empower is entirely voluntary. Failure to provide required information may hinder the processing of your application.

Sensitive Personal Information. Only to the extent permitted by applicable laws, Empower will collect and process a limited amount of personal data that may fall into a special category of personal data, sometimes called “sensitive personal data” or “sensitive personal information” such as the following:

Religion or philosophical beliefs;
Racial or ethnic origin;
Sex life or sexual orientation;
Precise location;
Health information;
Genetic or biometric data;
Login credentials;
Identification numbers such as Social Security Number, Driver’s License or State Identification Number, passport number; and
Criminal records and information regarding criminal offences or proceedings;

We only process such sensitive personal information where necessary for the purpose of carrying out the obligations and in compliance with applicable law.

Why We Collect Your Information. In addition to the purposes collected through the use of Empower’s website as outlined in Empower’s Privacy Policy, Empower collects and uses applicant personal information for the following business purposes:

To manage the job application process, including scheduling interviews and evaluating candidacy;
To communicate with applicants regarding your application status or job alerts as requested;
To support recruitment and hiring activities, including candidate evaluation and selection;
To conduct interviews and manage interview feedback and assessments;
To provide talent management services and activities;
To perform pre-employment and employment screening, as permitted by applicable law;
To facilitate onboarding processes, where applicable;
To support workforce planning, reporting, and analytics;
To monitor and ensure compliance with applicable laws and regulations;
To provide technical application support related to the job application process;
To communicate relevant career opportunities and build talent pipelines, where permitted;
To make offers of employment, where applicable;
To verify licensure and qualifications, where applicable;
To support identity verification and fraud prevention, where applicable;
To market career opportunities;
To support business transactions; and
To maintain records and support audits, legal claims, and the exercise of Empower’s rights and defenses.

If you provide us with personal information about dependents or family members, we will only use this information for the specific reason for which it is provided.

Empower may provide a separate AI consent form. AI technology may be used for the foregoing use collection and processing purposes. The vendors may have access to the information Empower collects. Empower’s third-party providers may also include integrations, references, or links to services provided by third parties whose privacy practices differ from Empower’s. If you provide personal information to any of those third parties, or allow Empower to share personal information with them, that information is governed by their privacy statements. The list of third-party vendors, including AI vendors, that Empower uses for applicants may be found here.

Empower reserves the right and may revise the list of third-party vendors as vendors are added or modified, modifications to information management are made, or as laws change that may impact Empower use of third-party vendor services.

How We Collect Your Information. We collect your information from:

Directly from you (whether in person, by telephone, email, text, and/or through our website and mobile apps, including through job applications, resumes/CVs, interviews, and communications with our recruiting team)
Publicly accessible sources, such as LinkedIn and other professional or social networking platforms.
Third parties, such as recruiters, employment agencies, referral sources, assessment vendors, affiliates, background check agencies (as applicable), and other business partners. This may include third-party artificial intelligence (“AI”) chatbots, wherein the chats utilizing the AI chatbot may be monitored, and the AI chatbot may store or process user interactions.
Automated means, through use of your mobile device, tablet, or other device or other technology such as when you visit our careers site or interact with job postings, emails, or other recruiting-related communications.
Internal referrals and candidate-provided references, where others share your information with us in connection with potential employment opportunities.
Our IT systems such as:
- Automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems
- Reception logs

2. Web Logs

Like most websites, Empower automatically gathers certain information. Empower maintains standard Web logs that record data about all visitors and customers who use Empower’s website and we store this information for no longer than reasonably useful to carry out its legitimate business purpose, or as legally required. This may include such data as the IP address which is automatically assigned to your computer when you get on the Internet, the type of browser and operating systems you use, pages you visit on the Careers Website, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Careers Website, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs, applications, or third-party applications that recognize your computer and gather information about its online activity.

3. Cookies

We and our service providers may place Internet “cookies” or similar technologies (ETag, JavaScript, HTML5) on the computer hard drives of applicants who visit Empower’s website. The website uses cookies to improve your experience and to understand how you interact with it. Empower collects two main categories of cookies: necessary cookies and non-necessary cookies. Necessary cookies are stored on your browser because they are essential for the operation of the website’s core functions. Non-necessary cookies are third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You have the option to opt-out of these cookies, but opting out of these cookies may affect your browsing and applicant experience.

As explained further below, third parties may also collect these types of information via Empower’s job postings through cookies, third party plug-ins and widgets. These third parties may collect data directly from your web browser, including from other apps and sites across the Internet, and the processing of this data is subject to their own privacy policies.

We and our third-party partners use cookies and web beacons to track our potential applicants’ usage of https://careers.empowerpharmacy.com/ (“Careers Website”). This enables Empower to provide services to potential applicants and improve the online experience. Empower also uses cookies and web beacons to obtain aggregate data about Careers Website traffic and interaction, to identify trends and obtain statistics so that Empower can improve our Careers Website. We also use cookies and similar technologies to target advertising and content.

Empower may use third-party analytics and advertising services, such as Google Analytics and its advertising products. The third-party analytics and advertising services may collect usage data, through cookies, web beacons, and similar tools about our Careers Website to provide us with reports and metrics that help us evaluate usage of the Empower Careers Website, improve performance and user experiences, and provide relevant advertising to you across the Internet. You can learn how Google collects and uses information at www.google.com/policies/privacy/partners.

Necessary Category: These cookies are essential for the website to function properly and only include cookies that ensure core functionalities and security features of the website. These cookies do not store any personal information. Because these are necessary you cannot opt out of these cookies. These cookies are retained only as long as necessary to support core website functions.

Non-Necessary Category: Non-necessary cookies are any cookies that may not be essential for the website to function and are used to collect user personal data via analytics, ads, and other embedded content. It is required to obtain user consent prior to running these cookies on your website. These cookies are retained according to analytics and advertising purposes, as specified in our privacy policy.

Consumer Rights: You have several rights regarding your personal information (there should be a separate opt-out link if cookies used for advertising are sold or shared)
1. Right to Know: You may request details on what personal information we collect, use, and disclose.
2. Right to Delete: You may request that we delete your personal information, subject to specific exceptions.
3. Right to Opt-Out: You may opt out of the sale or sharing of your personal information, including cookies used for advertising purposes.
4. Right to Correct: You may request correction of inaccurate personal information.
5. Web Beacons

The Careers Website, the emails that you receive from Empower, or third-party applications may use an application known as a “web beacon” (also known as a “clear gif” or “web bug”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it allows an email sender to determine whether a user has opened a particular email. If you have set your browser to decline or deactivate cookies, web beacons cannot function properly.

Disclosures

Empower may disclose personal information to data processors or service providers to process personal data on our behalf, including any person performing legal, operational, audit, law enforcement, or other services for Empower. Where reasonably possible, Empower will disclose information that does not identify an individual.

These services may include:

Interview scheduling;
Right to work confirmation services;
Background check providers;
Talent management providers;
Communication services, including SMS where you have provided consent;
Offering and management of Empower’s Careers Website;
Recruitment providers;
Marketing providers;
Survey providers;
Online advertising providers;
Data security and audit services;
Law enforcement services;
As required by law or to protect legal rights; and
To protect the health and safety of us and/or others.

Empower may also disclose your personal information at your consent or direction. In compliance with applicable law, Empower may enter into contracts with data processors or service providers to process your personal data only as necessary to perform services on our behalf and to implement appropriate data protection security measures. Empower or our service providers may also disclose personal data where required or permitted by applicable law.

International Data Transfers

Your personal data collected through the Empower Careers Website will be stored in databases used by the Talent Acquisition and Human Resources departments. The personal data collected on the Careers Website are typically stored on servers maintained by vendors in the United States of America.

To the extent that personal data is transferred to or accessed by data processors or from other countries, Empower will implement appropriate safeguards to ensure that your personal data remains protected. This includes signing Data Processing Agreement or Data Processing Addendum (DPA) as necessary to comply with applicable law.

Data Retention

We may retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy policy. This includes purposes such as meeting our legal obligations, resolving disputes, and enforcing our agreements. Where a longer retention period is required or permitted by law, we will retain the information. This may include retention of records for tax, accounting, or recordkeeping obligations. If you are not offered a position with Empower, we may contact you about future opportunities consistent with this policy and your expressed interests and qualifications. To the extent third parties request an extension of record retention, the retention and services provided by third parties is governed by their privacy statements.

SMS Text Messaging, Emails, and Voice Messages

Empower may choose to use other third-party service providers to help with some of our email and/or voice and text messaging communications with you. These service providers may collect and/or use your information to assist us in achieving the purposes discussed above in the section entitled “Information Collection Use.” While we do supply these vendors with email addresses or mobile telephone numbers of those we wish for them to contact, your email address or mobile telephone number is never used for any purpose other than to communicate with you on our behalf. When you click on a link in an email, you may temporarily be redirected through one of the vendor's servers (although this process will be invisible to you) which will register that you've clicked on that link and have visited our Careers Website.

At any time, and even if you have expressly given us permission to send voice/text messages to you, you may communicate your desire not to receive additional voice/text messages by following the stop or opt-out instructions in the voice or text message or by contacting support@empowerpharmacy.com.

Social Media

The Careers Website includes links to Social Media Features, such as X, Meta, Facebook, LinkedIn, and YouTube links. These may collect your IP address, which page you are visiting on our Careers Website, and may set a cookie to enable proper function. Your interactions with these social media sites are governed by the privacy policy or statement of the company providing them.

Location Services

The Careers Website may collect your precise device location using technologies like GPS, Wi-Fi, and Bluetooth, to help you find Empower locations or for third-party carrier apps. Your location may be used in real-time. User location data will not be stored.

You may opt in or out of location-based services by editing the App location setting on your device.

Websites and Applications for Third Parties

Our Careers Website may include links to other websites whose privacy practices may differ from those of Empower. If you elect to utilize third-party accounts or platforms to upload your resume data from a professional social network, Empower may share information with those third parties to allow you to benefit from these functionalities. If you submit personal information to any of those sites, your information is governed by their privacy policy or statement. We encourage you to carefully read the privacy statement of any website you visit.

At your request, we may send your personal information to other apps that are created and owned by a third-party such as a mail carrier. Empower has no control over third-party apps or app providers and is not responsible for the integrity, privacy, security or breach of data transferred to, or stored in the app, or the use or disclosure of data by the app or the app provider once the data are released by Empower. We encourage you to carefully review the terms of use and privacy policy and settings that apply to the third-party app and the app provider and approve release of data only to those apps and app providers that you trust.

Applicant Rights

Applicant Rights. The following applies to applicants generally in accordance with applicable law. Applicants have the right to:

Know what personal information is being collected and how it will be used.
Access their personal information.
Limit the use and disclosure of their sensitive personal information.
Know if their personal information may be shared with third parties.
Know what categories of their personal information may be shared with third parties.
Opt-out of receiving SMS communications.
Right to correct any inaccuracies in your personal data.

Additional California Privacy Rights

This California Applicant Privacy Policy and Notice at Collection (“Applicant Notice”) provides specific information for Applicants who are residents of California. If you are a California resident as defined in 18 Cal. Code Reg. §17014, and the processing of personal information about you is subject to the California Consumer Privacy Act (CCPA), you have certain rights with respect to that information.

This Applicant Notice is intended to satisfy applicable notice requirements under the California Consumer Privacy Act (“CCPA”) and it applies only to “personal information” as defined in the CCPA. We may refer to “personal information” as “personal data” in this Notice.

Information Collection

Personal Data Categories	Source of Collection
IdentifiersIncluding name, mailing address, email address, date of birth, username/password, telephone number, online identifiers, username and password, or other similar identifiers	From you or others working on your behalf. This may include recruiters.
Sensitive Personal InformationIncluding Identification numbers such as Social Security Number, Driver’s License or State Identification Number, passport number	From you.
Employment-related InformationIncluding licensure numbers (if applicable), employment history, professional memberships (if applicable), current and former employer(s) information, disciplinary record, or any other related information.	From you or others working on your behalf. This may include recruiters. From references. From publicly available sources.
Education InformationIncluding schools attended, dates of attendance, grades, transcripts, disciplinary records (if applicable), education records, or any other information you chose to provide.	From you or others working on your behalf. This may include recruiters. From references. From educational or certification institutions.
Protected Class CharacteristicsIncluding, race, citizenship, medical condition, health information, physical or mental disability, sex, sexual orientation, age, marital status, or other characteristics of protected classifications under California or federal law.	From you or others working on your behalf. This may include recruiters.
Internet Information and ActivityIncluding information relating to your search and browsing history and information relating to your interaction with our job postings, careers site, or job advertisements.	From you. From service providers. From social media, marketing, or advertising platforms.
Location InformationIncluding geographic location	From you or others working on your behalf. This may include recruiters.
Visual, Audio, or Similar Identifiers/InformationIncluding photographic, visual, audio, or video or similar information, including information collected via recorded calls, meetings, or videos, CCTV footage to secure our offices and premises, and website chatbot (if used).	From you. From service providers.
Profile and Associated InferencesIncluding inferences drawn from any of the information identified above to create a profile reflecting an individual’s preferences, characteristics, behavior or attitudes.	From you or others working on your behalf. This may include recruiters. From references.

How We Use Your Information

Empower collects and uses applicant personal information as described above for the following business or commercial purposes (and any directly related purposes), as further described in "Why we collect your information" above, including:

To manage the job application process, including scheduling interviews and evaluating candidacy;
To communicate with applicants regarding your application status or job alerts as requested;
To support recruitment and hiring activities, including candidate evaluation and selection;
To conduct interviews and manage interview feedback and assessments;
To provide talent management services and activities;
To perform pre-employment and employment screening, as permitted by applicable law;
To facilitate onboarding processes, where applicable;
To support workforce planning, reporting, and analytics;
To monitor and ensure compliance with applicable laws and regulations;
To provide technical application support related to the job application process;
To communicate relevant career opportunities and build talent pipelines, where permitted;
To make offers of employment, where applicable;
To verify licensure and qualifications, where applicable;
To support identity verification and fraud prevention, where applicable;
To market career opportunities;
To support business transactions; and
To maintain records and support audits, legal claims, and the exercise of Empower’s rights and defenses.
For general operational and business support; and
Other business purposes as identified in the CCPA.

Disclosures of Your Information

As described in “Disclosures” above, Empower may disclose, or have disclosed in the previous 12 months all categories of personal data listed above for a business or commercial purpose to the following categories of recipients:

To data processors and service providers;
To vendors;
To affiliates;
To law enforcement, regulators, or government entities;
To potential partners, advisors, partners or third parties with interest in connection with potential business transactions.
To others with your consent; and
To others as required by law.

Empower may also share your personal information as further described above, with advertising and marketing networks and social platforms for advertising. The CCPA may deem these types of disclosures of your personal information as a “sale” or “sharing,” but Empower does not otherwise sell personal information to third parties for money or other compensation.

Retention

California Applicant Rights

The following applies to California applicants (Applicants may find more information regarding their rights under the California Fair Employment and Housing Act.):

In accordance with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), applicants have the right to:

Know what personal information is being collected and how it will be used.
Access their personal information.
Request deletion of their personal information.
Opt-out of the sale or sharing of their personal information.
Limit the use and disclosure of their sensitive personal information.
Know if their personal information may be shared with third parties.
Know what categories of their personal information may be shared with third parties.
Right to correct any inaccuracies in your personal data.

Exercising Your Rights.

To exercise your rights under California law, you may:

Visit our website at https://www.empowerpharmacy.com/privacy-policy/.
Call our toll-free number at (877) 562-8577.
Email us at talentacquisition@empowerpharmacy.com.

When making a request, please provide your full name, contact information, and a description of the right you wish to exercise.

Exercising Your California Privacy Rights

To exercise your rights under California law, you may:

Visit our website at https://www.empowerpharmacy.com/privacy-policy/.
Call our toll-free number at (877) 562-8577.
Email us at talentacquisition@empowerpharmacy.com.

When making a request, please provide your full name, contact information, and a description of the right you wish to exercise.

Authorization

Before responding to a request to exercise your rights, Empower will need to first verify your identity using the personal data you provided to us. Empower will take steps to verify your request by matching the information provided by you with the information we have in our records. This may include but is not limited to verifying your name and email address. In some cases, Empower may need to request additional information to verify your identity, or where necessary to process your request.

Authorized Agent

You may designate someone as an authorized agent to submit data privacy requests and act on your behalf. Empower will require Authorized agents to provide proof of their authorization, and we may also require that the applicant directly verify their identity and the authority of the authorized agent.

Questions, Complaints, or Opt-out Requests

If you have any questions about this Policy or the application process, please call our toll-free number at (877) 562-8577 or email us at talentacquisition@empowerpharmacy.com

Empower Clinic Services, L.L.C.
7601 North Sam Houston Pkwy W, Ste 100
Houston, TX 77064