Platform Privacy Policy

OPT OUTS AND YOUR CHOICES OVER INFORMATION WE SHARE

You have various options to opt out of our Platform for targeted advertising. Opting out does not prevent you from seeing ads; it simply means that we will no longer collect data for the purpose of interest-based advertising or online behavioral advertising, and you will no longer receive ads based on your historical viewing interests, personal characteristics, consumer segments, or other information. You may still receive contextual ads, as described above.

Note that different devices require separate opt-outs because each device type uses different technologies, and many of the opt-out technologies available are browser- or cookie-based so they will only apply to those specific browsers or cookies.

Your options include:

  • DAA Opt Out. Because PulsePoint adheres to the DAA Self-Regulatory Principles, you can opt out of targeted advertising by participating companies (including PulsePoint) by clicking here
  • NAI Opt Out. You may also opt out of targeted advertising from PulsePoint and/or other advertising networks that are also members of the NAI. You may access the NAI’s opt-out tool here.
  • TV Opt Out. Many connected TVs and related devices offer a choice mechanism similar to those offered by mobile devices which PulsePoint will honor. In order to exercise your choices with respect to CTV or OTT devices, please visit: https://www.networkadvertising.org/internet-connected-tv-choices/.

The DAA and NAI opt-out tools are cookie-based. It signals your preferences to us so that we do not collect data online or deliver ads for the purpose of interest-based/targeted advertising. These tools will only function if your browser is set to accept third-party cookies. If you delete an opt out cookie or all cookies from a browser’s cookie files, change web browsers or change computers, you will no longer be opted out of our data collection and ad targeting, and we may place a new cookie unless an opt-out cookie is against reset on that browser. Opting out using one browser on one computer will not opt you out of using any other browser on the same or another computer.

If you are using a mobile device, your mobile device may offer settings to limit or disable mobile apps from gathering certain information. You should check the settings for the app and your device. PulsePoint honors the mobile device settings for Android and Apple iOS devices. To exercise this opt-out, please visit the privacy settings of your device and select “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android).

You may also set a preference on your browser through a browser-based opt out signal called “Global Privacy Control.” This signal is only available on certain browsers and is browser-specific, so it will only apply to the browser on which you opt to use it. However, PulsePoint honors this signal when it is passed through to us. You can learn more about GPC here.

LiveRamp

We may share information that we collect from you, such as your IP address or other information about your browser or operating system with certain service providers, including LiveRamp, Inc. LiveRamp returns an online identification code that we may store in our first-party cookie and it may be shared with advertising companies to enable interest-based and targeted advertising. You may opt out of this use here.

Healthcare Providers

If you are a healthcare provider (“HCP”) with a registered NPI number, you may request that your NPI number and other personal information be removed from PulsePoint’s NPI database at any time by submitting a request here.

EEA RESIDENTS

We do not intentionally process data of consumers in the EEA. However, if we receive data from a device located in the EEA, you will be afforded the rights provided under the GDPR. EEA residents are also able to access our Data Protection Officer, who is reachable at dpo.webmd.ams@dentons.com

If you are located in the EEA and visit a site or other content provider that happens to work with PulsePoint and uses the IAB Europe Transparency and Consent Framework, that publisher should provide you with an option to choose which third parties you wish to allow access to your device and information.

If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details provided under the “Who We Are” heading above. We may not hold any data about you but we will review your request and respond as appropriate.

In addition, if you are a resident of the EEA, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. Again, you can exercise these rights by contacting us.

Similarly, if we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

COLLECTION, USE, AND DISCLOSURE OF INFORMATION BY OTHERS

This Privacy Policy applies only to information gathered by us in connection with our Platform. There are other companies involved in collecting information and serving ads. The use of third-party pixels, cookies, and other technologies on websites that end-users visit, in apps that end-users use, and in ads served to end-users should be described by the privacy policies associated with those websites, apps, and ads. We have no responsibility for the collection, use, or disclosure of information by those third parties via such websites, apps, or ads.

SECURITY

We use reasonable security measures to protect the data in our possession. However, no method of transmission or storage of data is 100% secure. To the extent we provide your data to any third parties, we request that they use reasonable and industry standard security measures to protect your information.

DATA RETENTION

Information we acquire through our Platform is generally deleted within 45-60 days but may be retained in PulsePoint’s internal network for up to 18 months from the date of collection before deletion.

We retain information we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements).  

When we have no ongoing legitimate business need to process your data, we will either delete or anonymize it or, if this is not possible (for example, because your data has been stored in backup archives), then we will securely store your data and isolate it from any further processing until deletion is possible.

ACCESS, CORRECTION, AND DELETION REQUESTS

If you would like to access, correct, update, or request deletion of the data we have on file for you, you may submit such requests here. Alternatively, you may email us at privacy@pulsepoint.com or write to PulsePoint Privacy Department, 283-299 Market Street, 2 Gateway Center, 4th Floor, Newark, NJ 07102. We may take reasonable steps to confirm your identity in an effort to prevent identity theft. Also, please note that in general, we only have pseudonymous data on any given individual (other than HCPs) and may not be able to link any data we have to your personally identifiable data and as such, we may not be able to complete certain rights requests.

CHILDREN’S PRIVACY

In the interest of the privacy of children, we do not knowingly collect information from or target end users under the age of 16. Our Platform is neither developed for nor directed at children. If we learn we have collected or received information from a minor under 16 without verification of parental consent, we will endeavor to delete that information.

CROSS-BORDER DATA TRANSFERS

Our Platform is based in the United States and operates under United States law. If you are located outside of the United States, the information we collect may be transferred to and processed in the United States and in other countries where the privacy laws may not be the same as the laws where you reside and, in some cases, may not be as protective. Additional considerations apply to the collection, use, and disclosure of information from individuals who live in the EEA.

DO NOT TRACK (“DNT”) AND GLOBAL PRIVACY CONTROL (“GPC”)

Certain web browsers allow you to turn on settings that automatically send a signal to companies you interact with online to indicate you would like to opt out of having your data shared or sold. PulsePoint has implemented and will honor GPC. PulsePoint is also a signatory to the IAB’s MSPA and recognizes the GPP consent string in accordance with IAB guidance.  

RESIDENTS OF CALIFORNIA 

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”), we are required to disclose certain additional information to California residents. If you are a California resident, the information in this Section pertains to you.

In addition to the privacy rights listed below for certain US Residents, California Residents have the right to limit the use of sensitive personal information that we may collect about such residents. We generally do not attempt to collect any “Sensitive Personal Information” as defined under the CCPA, but we may be sent such information from publishers or other partners without prior notice. If we use or disclose this sensitive personal data for any reason other than as permitted under the CCPA, you have the right to request that we limit that use to only specific uses as prescribed under the CCPA.

California Disclosure

In the past 12 months:
Categories of Personal Information Collected

For Healthcare Providers Only: Identifiers such as name, postal address, telephone number, email, account name; Professional or employment-related information such as current place of employment; and all items collected below for consumers. 

For Consumers: Identifiers such as Cookies, IP address, Mobile Ad IDs, Timestamps, User Agent Strings, unique personal identifiers, online identifiers, IP address; Location Data such as general location data that is “imprecise” under applicable law or the NAI Code of Conduct, whichever radius is larger, as well as other location data that may be determined based on WiFi networks that may be inferred to provide “precise” location data; Internet and Electronic Network Information, such as information on a user’s interaction with a website, application or advertisement; and Inferences drawn from other personal information.

Please also see “Information We Collect” in the privacy policy above for more details.

Categories of Sources from which Information is Collected

Websites, mobile applications, technology platforms, other adtech providers, data providers, data brokers.

Purposes for Collecting and Disclosing Personal Information

We use collected information to provide online advertising services, as further described above in “How We Use Collected Information” and “How We Share Information”

Categories of Personal Information that we sell or share

Pursuant to the definition of “sell” under the CCPA, we “sell” only the personal information described for “Healthcare Providers Only” under the “Categories of Personal Information Collected” provided above in this chart. Pursuant to the definition of “share” under the CCPA, we share the information for both HCPs and Consumers under “Categories of Personal Information Collected” provided above in this chart

Third parties to whom information is shared or sold

Publishers, demand partners, supply partners, measurement providers, identity resolution partners, advertiser clients (for HCP data only)

Consumer Requests:

Received

Completed

Denied

Exempt under Cal. Civ. Code § 1798.145 / § 1798.146

Mean Number of Days to Respond

Median Number of Days to Respond

Delete

14

14

0

0

1.43

1

Know or Access

2

1

1

N/A

10

10

Opt-Out of Sale or Share

29

29

0

N/A

1.76

1

Correction

0

0

0

N/A

0

0

Limit Use of Sensitive Personal Information

1

1

0

N/A

0

0

Total Consumer Requests

46

45

1

0

2.02

1