Information we collect.
We have collected the following categories of information from consumers within the last twelve (12) months:
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.
B. Personal information listed under Cal. Civ. Code § 1798.80(e).
A 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. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial Information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric Information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information.
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Certain information that we collect identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”).
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information included in categories D and F is collected and used in a de-identified and/or aggregated manner.
- Information excluded from the CCPA's scope, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Categories of sources from which information is collected.
- Directly from you, such as when you register with us.
- Indirectly from you, such as information we may collect in the course of providing the Services.
- Directly and indirectly from your activity on our Sites.
- From third parties that interact with us in connection with the Services.
Use of personal information.
Your personal information included in each of categories A, B, I and K described above may be used for the following business purposes:
- completion and support of the activity for which the information was provided, such as allowing access to or delivery of our products or services and responding to your requests or inquiries;
- website and system administration, such as for the technical support of the Sites and its computer system, including processing computer account information, information used in the course of securing and maintaining our Sites, and verification of Site activity by such Site or its agents;
- research and development to enhance, evaluate and improve our Sites and our Services;
- tailoring or customizing content or design of our Sites during a single visit to our Sites and individualized personalization of our Sites on repeat visits;
- to create a profile used to determine the habits, interests or other characteristics of users for purposes of research, analysis and reporting;
- communicating with you about changes or updates to our Sites and our Services;
- communicating with you about special offers, promotions or market research surveys;
- to provide marketing and/or sales offers; and
- to provide news, informational and educational content.
In addition, we may use personal information about you for other purposes that are disclosed to you at the time we collect the information and/or with your consent.
Sharing your personal information
Personal information disclosed for a business purpose
We may share your information with our subsidiaries, affiliates and companies acquired by or merged with us and our affiliates.
We work with third party companies that help us provide the Services and to otherwise assist in the operation of the Sites, including those that provide services relating to technology, data analysis, research, email management and deployment, sweepstakes and contest administration, advertising and marketing and/or content. Our service providers sometimes have limited access to your information in the course of providing products or services to us. We contractually require that our service providers not use or disclose your information for any purpose other than providing the limited service or function for us.
In the preceding twelve (12) months, we have disclosed your personal information included in each of categories A, B, I and K for a business purpose.
We disclose your personal information for a business purpose to the following categories of third parties: (i) service providers, and (ii) third parties to whom you or your agents authorize us to disclose your personal information in connection with the Services.
Personal information “sold” to third parties
We may share information that we have about you, such as a cookie ID or IP address, with third party advertising partners who may use this information, on our behalf, to help us deliver advertising on the Sites as well as on third party websites.
In the preceding twelve (12) months, we have made available your personal information included in category A to third parties for advertising services.
We do not sell the personal information of consumers that we know are minors under 16 years of age without affirmative authorization as required under the CCPA.
The CCPA provides California consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to specific information and data portability rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- the categories of personal information we collected about you.
- the categories of sources for the personal information we collected about you.
- our business or commercial purpose for collecting or selling that personal information.
- the categories of third parties with whom we share that personal information.
- the specific pieces of personal information we collected about you (also called a data portability request).
- if we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- debug products to identify and repair errors that impair existing intended functionality.
- exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- 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 the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- comply with a legal obligation.
- make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Right to opt out of the sale of your personal information
You have the right to opt out of the sale of your personal information subject to certain exclusions as described below. Once we receive your request, we will not sell your personal information, unless an exclusion applies. We may request that you authorize the sale of your personal information after 12 months following your opt-out.
The CCPA excludes certain transfers of your personal information from what constitutes a sale thereof:
- As directed by you:
- When you direct us to intentionally disclose your personal information or use the Services to intentionally interact with us or a third party (provided that third party does not sell your personal information, unless that disclosure would be consistent with the CCPA).
- Opt-out signal:
- We may share an identifier for you if you have opted out of the sale of your personal information for the purposes of alerting third parties of your election.
- Service provider:
- We may share your personal information with a service provider that is necessary to perform a business purpose as described above if both of the following conditions are met:
- we provide notice of the sharing and your opt-out right as described herein.
- the service provider does not further collect, sell, or use the personal information of the consumer except as necessary to perform the business purpose.
- We may share your personal information with a service provider that is necessary to perform a business purpose as described above if both of the following conditions are met:
- Change of control:
- We may transfer to a third party your personal information as an asset that is part of a merger, acquisition, bankruptcy, or other transaction subject to certain requirements described in the CCPA.
We are unable to process opt-out requests across devices or the Apps for advertising services described herein. For example, if you opt out on your browser, we are not able to honor that request if you are using one of our Apps due to our practices and the limitations described above. Please see below on how to opt out across devices.
Exercising access, data portability and deletion rights
To exercise the access, data portability and deletion rights described above, please submit a request to us by either:
- Calling us at (866) 967-1410.
- Clicking here.
By calling the toll-free number or using the above link, you will be asked to provide certain identifying information, such as name, email, residency and date of birth, which we will only use to process or verify your request. You will be asked to validate your request by clicking a validation link in an email that will be sent to the email address provided.
The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
You may be asked to provide further verifying documentation, such as proof of residency and identity.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide proof of written authorization to do so, and you must verify your identity directly with us, unless such authorized agent provides proof of a power of attorney pursuant to Probate Code sections 4000 to 4465.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Exercising your opt-out right.
You may exercise your opt-out right by visiting the our website and clicking the “Do Not Sell My Personal Information” link in the footer.
Additionally, most browser software can be set to reject all cookies, including third party cookies, however, if you choose to reject our cookies, your ability to access and use the Services will be limited. Typically the cookie settings are within the “options” or “preferences” menu in your browser. The links below provide information about cookie settings for some commonly used browsers:
You can learn more about managing your preferences for ads online, particularly for many third-party advertising networks, through resources made available by the Digital Advertising Alliance at https://www.aboutads.info/ or the Network Advertising Initiative at https://optout.networkadvertising.org. Note that if you delete cookies, use a different device, or change web browsers, you may need to opt out again.
You may control interest-based advertising on your mobile device by enabling the “Limit Ad Tracking” setting in your iOS device’s settings or “Opt out of Ads Personalization” in your Android device’s settings. This will not prevent you from seeing advertisements, but will limit the use of device advertising identifiers to personalize ads based on your interests. If you have questions about how to reject cookies on your specific device please check with the device manufacturer.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will cover a period of no less than 12 months preceding the receipt of a verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
We may provide a different level of Services if the difference is reasonably related to value provided by your data.
Changes to this privacy notice
We reserve the right to change or modify this privacy notice and any of our Services at any time and any changes will be effective upon being posted unless we advise otherwise. By continuing to use the Services after changes are made to this privacy notice, you agree to such changes. We encourage you to periodically review this privacy notice for the latest information on our privacy practices.
Please send us an email by using the Contact Us link at the bottom of every page of the Sites if you have any questions about this privacy notice or the personal information we maintain about you. We will respond to your request within a reasonable timeframe.
You can also contact our Privacy Office at:
Frontline Medical Communications, Inc. c/o WebMD LLC
Attn: Office of Privacy
1201 Peachtree Street, NE
400 Colony Square, Suite 2100
Atlanta, GA 30361
Phone: (866) 967-1410
Effective Date: January 1, 2020