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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: http://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/index.php/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.

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

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/index.php/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/index.php/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

 

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