Stokes Healthcare Inc. and its two divisions Epicur Pharma® and Stokes Pharmacy® are committed to the safety and security of your data. To help you understand how we protect your information, below we have listed the details of why we need it and how we use it:
How we use your information:
Below is a list of ways we use your data and why.
Your rights:
The following rights relate to your personal information and the rights to request, amend and otherwise control that information that we extend to all of our customers subject to the limitations of any applicable federal, state and local laws and regulations:
Disclosing your information:
Your personal data, including name, address, or email information, will never be sold to third parties. Your information will only be used in conjunction with service providers who help us run our business and make it possible to get you the information you have requested, including social media sites. These service providers include the companies that host and protect our websites and online tools and, for our GFI #256B Comment Letter Tool, the provider of the artificial intelligence (AI) model that drafts your letter.
Marketing Messages:
If you have agreed to receiving information, we will send you marketing emails to keep you up to date on our latest company news and to help you keep up with industry trends.
You can choose to stop receiving marketing messages from our team at any time by unsubscribing. You can also hit “unsubscribe” from any email you have received from us. Your preferences will automatically be updated, and we will respect your choice to not receive further marketing messages.
Keeping your information:
Your information will be on record for as long as it is needed in order to provide you with the services you have inquired about or to provide you with information you have requested. Information entered into our GFI #256B Comment Letter Tool is not stored by us and is handled as described in the section of that name below.
Changes to how we protect your privacy:
From time to time, we may make changes to this page as we make updates to how your data is processed. If the changes are significant, we will make you aware of that on our websites or in other forms of contact such as email. In these cases, you will be able to review the changes before you continue using our websites.
Cookies:
We use cookies on our website to help us make sure you receive the best browsing experience based on your needs and preferences. Below are the four primary types of cookies and why each is important:
When using our site, you can choose to allow or disable the placement of these cookies on your device. If cookies are deleted or disabled, your user experience may be affected.
GFI #256B Comment Letter Tool:
Epicur Pharma, a division of Stokes Healthcare Inc., provides an online tool (the “Comment Letter Tool”) that helps veterinarians and other members of the public draft their own comment letters to the U.S. Food and Drug Administration (FDA) on draft Guidance for Industry #256B (Docket No. FDA-2018-D-4533). This section explains how we handle information entered into the Comment Letter Tool. If anything in this section conflicts with the rest of this policy, this section controls for the Comment Letter Tool.
What we collect. When you use the Comment Letter Tool, we collect:
We do not ask for, and you should not enter, information about your clients or patients, such as pet owners’ names, contact details or medical records, or any other person’s personal information. Please also do not enter professional license numbers, social security numbers, financial account information or health information about yourself or anyone else.
How we use it. We use the information you enter only to generate a draft letter for you, at your request, and to protect the tool from misuse (for example, through rate limits and bot protection). We do not use it for marketing or sales, and we do not add you to any mailing or contact list unless you separately check a box agreeing to receive communications from us where that option is offered.
Who processes it. To generate your draft, the information you enter is sent to Anthropic, PBC, which provides the AI model (Claude) that writes the draft. The tool is hosted by GoDaddy.com, LLC, our web hosting provider. Cloudflare, Inc. runs the bot-protection (CAPTCHA) check; it uses your IP address, browser information and the address of the site the check comes from to tell people from automated programs, and does not receive the text of your letter or your story. Cloudflare also uses limited technical data from the check, such as your IP address and browser details, under its own privacy terms to improve its bot detection. Anthropic, GoDaddy and Cloudflare act as our service providers and are bound by data processing terms that limit how they may use your information, except for Cloudflare’s use to improve its bot detection described above. Under its commercial terms, Anthropic does not train its AI models on information submitted through our account.
How long it is kept. We do not store the letters generated by the Comment Letter Tool, or the information you type into it, in our own systems. If you leave or refresh the page before copying or saving your draft, the draft is gone. Anthropic automatically deletes the information sent to it and the drafts it generates within 30 days, except that it may keep content flagged as violating its usage policies for up to two years, or longer where required by law. To limit misuse, the tool keeps a one-way coded identifier derived from your IP address, together with a count of your drafts, for no more than one hour; it does not keep your IP address itself. Technical logs kept by us and our hosting provider, GoDaddy.com, LLC, for troubleshooting and security, which record information such as your IP address, the time of your request and the page requested, are kept according to GoDaddy’s standard practices and only as long as reasonably needed for those purposes. The tool is designed so that the text of your letter and your story are not written to our logs.
Your comment becomes public when you file it. The Comment Letter Tool does not submit anything to FDA for you. You decide whether to file your letter, and you file it yourself. Comments filed in an FDA docket, including your name and any other information in your letter, are generally posted publicly on www.regulations.gov and become part of the public record. We cannot remove a comment from the public docket once it has been filed, so include only information you are comfortable making public.
AI-generated drafts. Drafts are written by AI and may contain errors. You are the author and signer of your comment. Review, edit and verify every statement in the draft before you rely on it or submit it.
Your rights described in this policy, including the rights of California residents below, apply to information collected through the Comment Letter Tool. Because we do not store the content you enter, we will generally have no letter or story content to provide, correct or delete in response to a request.
California Residents
Last Updated: 10/16/2026
This section explains the rights of California residents regarding the collection, use, sale, and sharing of their personal information under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We may update and make changes to this section, so we encourage you to review it periodically.
We, us, our | Stokes Healthcare Inc. (D/B/A Stokes Pharmacy and D/B/A Epicur Pharma) |
Personal information | Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household. |
Sensitive personal information | Personal information revealing a consumer’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer’s health, sex life, or sexual orientation, contents of a consumer’s mail, email and text messages where the business is not the intended recipient, genetic data, and biometric information. |
Biometric Information | An individual’s physiological, biological, or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. |
We do not intend to collect sensitive personal information through our GFI #256B Comment Letter Tool and ask that you not enter any. We do not store the content you enter into that tool; see “GFI #256B Comment Letter Tool” above and “How Long Your Personal Information Will Be Kept” below. Any information you choose to include in a comment letter that you file with FDA is made public by FDA, not by us.
Categories of Personal Information | Specific Types of Personal Information Collected |
Identifiers (e.g., 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) | Name, image, postal address, IP address, email address, account name, and professional license number. Users of our GFI #256B Comment Letter Tool: name, practice address, IP address, and a one-way coded identifier derived from IP address that is kept for no more than one hour to limit misuse. |
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | Telephone number, employment, medical information (COVID), credit card information. |
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) | Record of products purchased. |
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement) | Cookies for; website functionality, website analytics, customer preferences, targeting and advertising. Users of the GFI #256B Comment Letter Tool: IP address, browser and device information, and bot-protection signals used to prevent automated misuse of the tool. |
Geolocation data | Website functionality, website analytics, customer preferences, targeting and advertising. |
Professional or employment-related information | Practitioner license information. (For RACE CE credit and order fulfillment) Users of the GFI #256B Comment Letter Tool: credentials, title, practice name, practice type, and the professional experience and views you choose to include in your comment letter. |
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for | Our reasons |
To provide products or services to you. | For the performance of our contract with you or to take steps at your request before entering into a contract |
To generate a draft FDA comment letter at your request through our GFI #256B Comment Letter Tool | Where you have given consent, by entering your information and asking the tool to draft a letter For our legitimate interests or those of a third party, i.e., to help veterinarians and others take part in FDA’s public comment process on matters that affect the availability of compounded animal drugs |
To prevent and detect fraud against you or Stokes Healthcare Inc. | For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you |
Conducting checks to identify our customers and verify their identity. Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulators. | To comply with our legal and regulatory obligations |
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
Ensuring business policies are adhered to, e.g., policies covering security and internet use | For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you |
Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures. | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
Preventing unauthorized access and modifications to systems | For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations |
Protecting our GFI #256B Comment Letter Tool from automated misuse, including bot protection and rate limiting | For our legitimate interests or those of a third party, i.e., to keep the tool available and secure and to prevent misuse |
Updating customer records | For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products |
Marketing our services and those of selected third parties to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings. | For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers |
Credit reference checks via external credit reference agencies | For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services |
External audits and quality checks, e.g., for accreditations and the audit of our accounts | For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to disclose some personal information to other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
GFI #256B Comment Letter Tool. We do not store the letters generated by the Comment Letter Tool or the information you enter into it in our own systems. Our AI service provider, Anthropic, PBC, automatically deletes those inputs and outputs within 30 days, except that it may retain content flagged as violating its usage policies for up to two years, or longer where required by law. The tool keeps a one-way coded identifier derived from your IP address, used only to limit misuse, for no more than one hour. Technical logs kept by us and our hosting provider, GoDaddy.com, LLC, for troubleshooting and security are kept according to GoDaddy’s standard practices and only as long as reasonably needed for those purposes. The tool is designed so that the text of your letter and your story are not written to our logs. Comment letters you choose to file with FDA are held by FDA, not by us, and are generally made public on www.regulations.gov.
Disclosure of Personal Information We Collect About You | You have the right to know, and request disclosure of:
• The categories of personal information we have collected about you, including sensitive personal information; • The categories of sources from which the personal information is collected; • Our business or commercial purpose for collecting, selling, or sharing personal information; • The categories of third parties to whom we disclose personal information, if any; and • The specific pieces of personal information we have collected about you.
Please note that we are not required to:
• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or • Provide the personal information to you more than twice in a 12-month period. |
Disclosure of Personal Information Disclosed for a Business Purpose | In connection with any personal information we may disclose to a third party for a business purpose, you have the right to know:
• The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared; and • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.
You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.
To opt-out of the sale or sharing of your personal information, visit our homepage and click on the Do Not Sell or Share My Personal Information link here: https://stokeshealthcare.com/do-not-sell-or-share/. |
Right to Limit Use of Sensitive Personal Information | You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:
Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; and As authorized by further regulations
You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.
To limit the use of your sensitive personal information, visit our homepage and click on the “Limit the Use of My Sensitive Personal Information” link here: https://stokeshealthcare.com/limit-use-of-sensiitive-personal-information/ |
Right to Deletion | Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
• Delete your personal information from our records; and • Direct any service providers or contractors to delete your personal information from their records. • Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.
Please note that we may not delete your personal information if it is reasonably necessary to:
• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; • Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes; • Debug to identify and repair errors that impair existing intended functionality; • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; • Comply with the California Electronic Communications Privacy Act; • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us • Comply with an existing legal obligation; or • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. |
Right of Correction | If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information. |
Protection Against Retaliation | You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: • Deny goods or services to you; • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; • Provide a different level or quality of goods or services to you; or • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information. |
Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly by [website/email/phone/in writing], you will need to provide us with:
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
Have more questions?
Contact us with any questions you have via email or by phone:
Licensing@StokesHealthcare.com | 888-508-5032