ConneXion360 Privacy Policy

Last Updated April 19, 2021

Supplemental Privacy Notices
Privacy Notice for California Residents
Privacy Notice for Nevada Residents

Treatment Perspectives, Practice Perspectives, Scientific Perspectives, and mChat are service marks of ConneXion360, LLC.

ConneXion360, LLC, 14901 Quorum Drive, Suite 650, Dallas, TX 75254, and its affiliates, subsidiaries, and divisions (collectively, the “Company,” “we,” “us,” and “our”). We have prepared this Privacy Policy to describe how we collect, process, and share information provided or collected on ConneXion360 websites where it is posted. Know that in addition to this website, ConneXion360 maintains a series of other sites under various proprietary titles created to support client marketing campaigns. These are collectively referred to as “microsites” throughout this document. This Privacy Policy links to those microsites and is applicable to all microsites as well as mobile versions of all ConneXion360 controlled websites where this Privacy Policy is posted.

ABOUT CONNEXION360
As an omnichannel marketer focused exclusively on providing marketing services (“Campaigns”) for biopharmaceutical companies (“Clients” or ‘Customers”) seeking to engage with Healthcare Professionals (“HCPs”), ConneXion360 communicates with HCPs through a variety of marketing channels. We collect personal information that specifically identifies an individual (such as a name or email address) through an opt-in process whereas to include HCPs in promotional efforts. We may also acquire personal information, or have it provided by a Client, from third party sources which include personal information on overall prescribing behavior, opted-in email addresses, professional demographic data, medical claims data, lab testing, and other similar data sets.

Through the execution of a Campaign, we collect promotional response data which includes, but isn’t limited to, email deliverability, email open and click rates, direct mail response rates, website browsing activity within our controlled microsites, targeted print and digital advertising, and other usage and device/location information. As data is collected directly, passively, or via third parties, ConneXion360 combines this data to create a profile of overall promotional responsiveness at both individual and aggregate levels.

We will provide both aggregate and personally identifiable promotional response data to our Clients and their approved suppliers as part of our overall marketing services.

While ConneXion360 does sell this information to our Clients as part of a specific Campaign, we do not sell access to our entire database of personal information as a stand-alone service.

INFORMATION COLLECTED

INFORMATION ACTIVELY SUBMITTED
In the course of visiting one of our microsites, we may ask you to provide us with certain personally identifiable information. The personal information we collect may include your name, mailing address, phone number, email address, and certain information related to your profession (specialty, hospital affiliation, etc).

USAGE INFORMATION
In addition to the promotional response data collection procedures indicated above, when you visit our microsites, we may also collect information relating to how you access and use our microsites. We collect this information using various approaches and tracking technologies, including but not limited to: browser cookies, web beacons, embedded tracking pixels, and other standard tracking methods including Google Analytics.

INFORMATION COLLECTED FROM OTHER SOURCES
Where permitted by applicable law, we may supplement your information with information we obtain from other sources, including but not limited to: (a) companies that provide our products or services by way of a co-branded or private-labeled website, (b) companies (eg, health care, pharmaceutical, and medical device entities) that sponsor our Campaigns, (c) companies that license and/or sell personal and/or usage information, or (d) professional organizations, such as the American Medical Association, which we will add to the information which we already hold about you.

INFORMATION COMBINED
We may combine information that we have collected offline with information we collect online about you, or we may combine information we get from a third party with information we already have.

HOW WE USE YOUR INFORMATION
We may use your information in several ways:

To respond to your requests or questions. For example, we might use your information to respond to your comments or feedback. We might also contact you about this Privacy Policy or our Terms of Use.
To improve our products and services. We might use your information to customize your experience with us. We may also use your information to improve our website, products, and services.
For security purposes. We may use your information to protect our company and our customers. We also use information to protect our websites and platforms.
For marketing purposes. For example, we might provide you with information about new Campaigns. We might also use your information to serve you ads supporting Campaigns.

HOW WE SHARE YOUR PERSONAL INFORMATION
We share your information with third parties only in the ways that are described in this Privacy Policy or as otherwise permitted or required by applicable law:

Affiliates, Subsidiaries, and Divisions. In order to provide you with services, we may share your information with our affiliates, subsidiaries, and/or divisions (eg, those companies related to us by common ownership or control) for everyday business purposes, in which case we will require our affiliates, subsidiaries, and divisions to comply with this Privacy Policy.
Third-Party Service Providers. We may also share your information with our suppliers, vendors, agents, contractors, or other companies or individuals that provide services to us or on our behalf. For example we share information with vendors who send emails, manage websites, distribute postal mail, facilitate online ad targeting, or process payments for us. We require these third-party service providers to protect your information with the same or equivalent safeguards as those in this Privacy Policy, and we do not permit them to use or disclose your information other than to provide the services requested by us.
Business Partners. We may disclose your information with our Clients with whom we collaborate solely for activities related to a Campaign or those jointly offered or developed by us and that Client.
Continuing Medical Education Providers. There are specific limited instances when your information may be shared with accredited Continuing Medical Education (“CME”) providers for their fulfillment of their reporting obligations to the Accreditation Council for Continuing Medical Education (“ACCME”) and global equivalent accrediting bodies. We do not control the privacy practices of these third parties.
As Required or Appropriate by Law. We may use or disclose your information if we believe in good faith that such use or disclosure is necessary: (a) to help identify any person attempting to break into or damage our websites or other property; (b) to investigate, prevent, or mitigate illegal activities; (c) to comply with applicable law; (d) to respond to valid subpoenas or warrants served on us (including our affiliates, subsidiaries, and divisions); or (e) to protect or defend our rights and/or property.

PROTECTION OF YOUR INFORMATION
We have a number of security measures in place to protect your information from unauthorized access, disclosure, alteration or destruction. These measures include the use of firewalls, secure connections on our websites, and frequently the use of Secure Sockets Layer (SSL) to encrypt pages that collect information. However, we cannot promise that your use of our Services will be completely safe. We encourage you to use caution when using our Services. This includes not sharing your passwords.

CHOICES
As described above, and in accordance with applicable law, we may provide you (via email, mail, digital ad, phone, fax, or similar technologies) general marketing and/or Campaign related communications (“Communications”). When you receive Communications from us, you may indicate a preference to stop receiving further Communications from us by “opting-out”: (a) via the unsubscribe instructions provided in the email you receive; or (b) by contacting us directly as provided under the “Contact Us” heading below.

Despite your indicated email preferences, we may send you notice of any updates to our Privacy Policy and other service-related, non-marketing, and transactional communications

LINKS TO OTHER WEBSITES
Our microsites and/or Communications may contain links to other third-party websites and online services. If you choose to visit a third-party website and or online service by clicking a banner ad, email link, or other links, you may be directed to that third party’s website or online service. The fact that we provide a link to a website’s content or online service or present a banner ad or other type of advertisement is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. This Privacy Policy is not applicable to the websites or online service or content of any such third parties and we do not exercise control over third-party websites or services. We encourage you to read the privacy policies of any such third-party websites and services.

CHILDREN’S INFORMATION
We do not knowingly collect or maintain personally identifiable or other information from any person under the age of majority. No parts of our websites, products, or services are designed to attract anyone under the age of 18.

DMD HEALTHCARE COMMUNICATIONS NETWORK PRIVACY STATEMENT
The Company participates in the DMD Healthcare Communication Network (the “Network”), and as such has implemented various technologies for universal registration/login among all Network member websites. These technologies are managed by DMD Marketing Corp. (“DMD”), and may involve the collection, receipt, and sharing of information with DMD, its clients and other Network members. If you would like to understand how this digital service’s participation in the Network affects your privacy, please click here: https://usersupport.dmdconnects.com/PrivacyPolicy.htm

Please note that the Network registration/login system may be different from the registration/login used by this digital service for other products and services. To the extent that anything in this privacy policy conflicts with the policy for the Network technologies, the conflict will be resolved in favor of the policy applicable to the Network technologies.

CHANGES TO THIS PRIVACY POLICY
We reserve the right to make changes to this Privacy Policy from time to time.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Last Updated July 29, 2020

This Privacy Notice for California Residents supplements the information contained in the ConneXion360 Privacy Policy (above) and applies only to California residents (“You,” “your” or “consumer”).

PERSONAL INFORMATION COLLECTION AND PURPOSES OF USE
We collect and use information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your devices when you visit this website or our microsites, provide us your personal information, or have a contractual or business relationship with us or any of our affiliates, (“Personal Information”). Such Personal Information includes direct identifiers including but not limited to a name, postal address, email address, government identifier, and indirect identifiers that may identify, relate to, or be associated with a particular individual, such as a telephone number, device identifier, IP address and browsing history.
We collect this Personal Information for the following purposes:

To respond to your requests or questions. For example, we might use your information to respond to your comments or feedback. We might also contact you about this Privacy Policy or our Terms of Use.
To improve our products and services. We might use your information to customize your experience with us. We may also use your information to improve our website, products, and services.
For security purposes. We may use your information to protect our company and our customers. We also use information to protect our websites and platforms.
For marketing purposes. For example, we might provide you with information about new products and special offers. We might also use your information to serve you ads about products and offers. We might tell you about new features or updates. These might be third-party offers or products we think you might find interesting. To learn about your choices for these communications, including our emails, read the “CHOICES” section above.

OUR PERSONAL INFORMATION HANDLING PRACTICES
In the preceding 12 months, we have collected the following categories of Personal Information from California residents:

Direct identifiers as described above
Indirect identifiers as described above

We have collected such Personal Information from one or more of the following categories of sources:

Information that you submit or share directly with us, through registrations, surveys, applications, or telephone calls, and email and postal communications
Information passively collected from cookies and other website analytics
Information collected through third parties or from your browsing activity on other sites, such as on social media platforms, and public databases
From one or more of our affiliates with which you have a business relationship
Service providers with which we have a contractual relationship and to which you have provided your Personal Information

We collected such Personal Information for the purposes noted above (see “Personal Information Collection and Purposes of Use”) and in the ConneXion360 Privacy Policy (see “How We Use Your Personal Information” and “How We Share Your Personal Information”). We may have shared such Personal Information with the following categories of third parties:

Vendors that help us track the effectiveness of our digital media initiative
Vendors that help us to provide you with programs, services or educational information we believe may be of interest to you
Clients who sponsor our services or on whose behalf we provide services to you
Affiliates and subsidiaries that may have or may want to seek a business relationship with you

We collected one or more of the following specific pieces of personal information:

Legal name, signature, email address, postal address, National Provider Identifier, geolocation data
Online identifier, Internet Protocol address, Internet or other electronic network activity information, including, but not limited to, browsing history, and information regarding your interaction with our Internet Web site(s), application, or advertisement

We may share your personal information with our affiliates, Clients and trusted partners in arrangements that may meet the broad definition of “sale” under California law. In these arrangements, use of the information we share is limited by policies, contracts, or similar restrictions.

In the preceding 12 months we may have disclosed, shared or sold, as defined by California law, one or more of the above categories of personal information.

YOUR PRIVACY RIGHTS
You have the following rights regarding our collection and use of your personal information. To exercise those rights, you must submit a request by either calling us at 1-877-238.8500 or through https://connexion360.com/privacy-request/. We may ask you to provide additional information to verify your request. We may not discriminate against you if you exercise your rights as described in this notice. For example, we may not deny goods or services to you or provide a different level of quality of products or services.

RIGHT TO INFORMATION
You have the right to request the following information regarding the personal information we have collected about you:

Categories of personal information collected about you, and sources from which collected
Our purpose for collecting personal information
Categories of third parties with which the personal information was shared
Specific pieces of personal information collected about consumers

You have the right to request the following information regarding the personal information we have sold or disclosed about you:

Categories of your personal information sold in the preceding 12 months
Categories of third parties to whom your personal information has been disclosed
Categories of personal information that we disclosed about consumers for a business purpose

RIGHT TO OPT OUT OF SHARING, DISCLOSURE, OR SALE OF PERSONAL INFORMATION
You have the right to direct us to not share, disclose, or sell your personal information.

RIGHT TO REQUESTS DELETION
You have the right to request that we delete the personal information we have about you. However, we are not required to delete information if it is necessary to retain your information to:

Complete the transaction for which the personal information was collected, provide a good or service requested by you, or a transaction reasonably anticipated within the context of our or one of our affiliates’ ongoing business relationship with you, or to otherwise perform a contract we have with you
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for that activity
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 pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code
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 deletion of the information is likely to render impossible or seriously impact the achievement of such research, if you have provided informed consent
Facilitate solely internal uses that are reasonably aligned with your expectations based on your relationship with us or one of our affiliates
Comply with a legal obligation
Otherwise use the personal information, internally, in a lawful manner that is compatible with the context in which it was provided

PRIVACY NOTICE FOR NEVADA RESIDENTS
Last Updated July 29, 2020

This Supplemental Privacy Notice for Nevada Residents adds to the information contained in the ConneXion360 Privacy Policy (above) and applies only to Nevada residents (“you,” “your,” or “consumer”).

PERSONAL INFORMATION COLLECTION AND PURPOSES OF USE
We collect certain personal information of Nevada consumers through our Internet websites or other online service. This information may include, but is not limited to, one or more of the following elements of personally identifiable information:

A first and last name
A home or other physical address that includes the name of a street and the name of a city or town
An electronic mail address
A telephone number
An identifier that allows a specific person to be contacted either physically or online
Any other information concerning a person collected from the person through ConneXion360 websites or online service of ConneXion360, and maintained by ConneXIon360 in combination with an identifier in a form that makes the information personally identifiable

We collect this personal information for the following purposes:

To respond to your questions or requests. For example, we might use your information to respond to your comments or feedback. We might also contact you about this Privacy Policy or our Terms of Use.
To improve our products and services. We might use your information to customize your experience with us. We may also use your information to improve our website, products, and services.
For security purposes. We may use your information to protect our company and our customers. We also use information to protect our websites and platforms.
For marketing purposes. For example, we might provide you with information about new products and special offers. We might also use your information to serve you ads about products and offers. We might tell you about new features or updates. These might be third-party offers or products we think you might find interesting. To learn about your choices for these communications, including our emails, read the “CHOICES” section below.

Vendors that help us track the effectiveness of our digital media initiative
Vendors that help us to provide you with programs, services or educational information we believe may be of interest to you
Clients who sponsor our services or on whose behalf we provide services to you
Affiliates and subsidiaries that may have or may want to seek a business relationship with you

YOUR PRIVACY RIGHTS
Right to access and/or correct your personal information, or opt out of sale of personal information

If you would like to review, correct, or update your personal information, you or your authorized representative may submit your request to https://connexion360.com/privacy-request/. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.

Under Nevada law, you have the right to direct us to not sell or license your personal information to third parties. To exercise this right, if applicable, you or your authorized representative may submit a request to https://connexion360.com/privacy-request/. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.

CONTACT US
ConneXion360, LLC
Attn: Customer Service
14901 Quorum Drive, Suite 650
Dallas, TX 75254
Phone: 877.238.8500
Email: customerservice@connexion360.com