HCP Privacy Policy

HCP Privacy Policy

Data360, provided by Collaborative Marketing Solutions (CMS), is committed to protecting your privacy and the privacy of others. Please read this Privacy Policy in reference to the Data360 website and services. By using this website or any of Data360’s services, you consent to the use by CMS, its affiliates and third-party vendors of any information or content you submit through the website or pursuant to the provision of services by CMS in the manner described in this Privacy Policy.

Questions Regarding Privacy Policy

If you have any questions or concerns regarding our current Privacy Policy please email us at [email protected].

Information We Collect From Healthcare Professionals (“HCPs”) Opt-Ins

Data360 may ONLY rent, license or sell the following PII (Personal identifiable Information) of HCPs who have actively opted-in to the Data360 HCP Email Database : Name,Title, primary specialty, secondary specialty, group practice size, group practice specialty, and type of facility. You are asked to identify which market verticals (Pharmaceutical, Insurance, Medical Device, CME, Publishing, etc.) from which you would like to receive 3rd party email solicitation.

Note: We periodically update our records using additional permission-based details and opt in by using a variety of data sources including online purchases of relief products, counseling, insurance and procedure prep, online support groups, self-reported survey data, postal surveys, phone surveys, email surveys, online search inquiries based specifically on the ailment, and shared and available insurance details. 

Opt-Out Process

An opt-out page is provided to enable members of the Data360 HCP Database to opt out at any stage from receiving 3rd party email solicitation from any of CMS’ partners. Healthcare professionals are given the opportunity to indicate if they wish to stop receiving 3rd party email solicitation from all market verticals or from specific market verticals.

How Does Data360 Use the Information It Collects?

Data360 may rent, license or sell the following personally identifiable information: email address, postal address, telephone number, fax number, specialty information, and group practice information, only from those specific healthcare professionals who have actively opted-in totheData360 HCP Email Database. Data360 will only rent, license or sell personally identifiable information to those specific market verticals that you have approved.

Disclosure to Third Parties

Data360 may share some kinds of personally identifiable information with third parties as described below.

Companies and People Who Work for Us:

CMS contracts with other companies and individuals to help us provide our services. For example, we may host some of our professional websites on another company’s computers, hire technical consultants to maintain any web-based health tools, or work with companies to remove repetitive information from customer lists, analyze data or provide marketing assistance (including assisting us in targeting our advertisements as described herein), customer service or fulfillment services.

In addition, if you are a healthcare professional, we may validate your licensure status and other information against available databases that list licensed health care professionals. In order to perform their jobs, these other companies may have limited access to some of the personally identifiable information we maintain about users of the professional websites. We require all such companies to comply with the terms of this Privacy Policy, to limit their access to any personal information to the minimum extent necessary to perform their obligations, and not to use the information they may access for purposes other than fulfilling their responsibilities to us.

Promotional Offers:

Sometimes Data360 sends offers to selected users or clients of CMS services on behalf of other businesses. When we do so, we do not give such businesses your name and address. If you do not wish to receive such third party offers, you may contact CMS at the email or postal address below and request removal from these promotional offers.

Assignments:

If CMS transfers or assigns a business unit (such as a subsidiary) or an asset (such as a web site) to another company, that company will be required to honor the applicable terms of Data360’s then-current Privacy Policy and associated privacy and data handling practices and procedures.

Legal Requirements:

We may release account and other personally identifiable information when we believe release (1) is required to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (2) is reasonable in response to a physical threat to you or others, to protect property or defend or assert legal rights. In the event that we are legally compelled to disclose your personally identifiable information to a third party, we will attempt to notify you unless doing so would violate the law or court order.

In addition, and without limiting our foregoing obligations, CMS may be required under law to report breaches by CMS or CMS’ affiliates, partners, vendors or clients, to the applicable privacy or data protection authorities. Such authorities are empowered to bring civil and criminal action, including imposing financial penalties, against any party misusing or failing to adequately protect or secure personal information.

Your Obligations

If you are a user of, or subscriber to, CMS’ services, including licensed use of Data360 databases or other Data360 proprietary information, either directly with CMS or through a CMS partner, you are strictly prohibited from using Data360 data or information beyond the licensed use restrictions between you and CMS and/or you and a CMS partner, including, without limitation, any applicable term (period of time) of licensed use. Upon expiration or termination of any such licensed use rights, you must either delete or return (without retention of a copy), at the direction and sole discretion of CMS, any data or other information acquired from CMSor a CMS partner, and certify in writing by registered postal or courier service to CMS and/or the applicable CMS partner that such actions were taken.

You agree that your (i) failure to delete or return, at CMS’ direction, and certify such deletion or return, or (ii) continued use of Data360 data or information after expiration or termination of your licensed use rights is subject to monetary damages equal to three times the license fees paid by you for such licensed use rights.

Consent:

By providing your personally identifiable information through the Data360 website or by using Data360 services, you consent to CMS providing your information to a third party solely for the purposes and subject to the limits described in this Privacy Policy. For example, when you choose to participate in a CMS “Industry Program,” we will provide certain personally identifiable information to the sponsor of such program, as further described above.

Does Data360 Use “Cookies”?

When Data360 sends a third party an informational email message on behalf of one of its clients/partners, we may insert a ”cookie” for tracking purposes. The ”cookie” will only be used to determine which healthcare professional has opened or clicked on an informational email message.

How Does CMS Protect Your Information?

CMS safeguards the security and accuracy of the data you send us with physical, electronic, and managerial procedures.

These procedures include limiting access to the information in various ways depending on the nature of the information as well as training our employees on the proper handling of subscriber and client information. While we believe we have taken appropriate measures to protect the information that we have received, we urge you to take every precaution to protect your personal data when you are on the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser.

When you place orders or access your account information, we offer the use of a secure server. The secure server software (SSL) encrypts all information you input before it is sent to us. Furthermore, we take extra steps to protect this data from unauthorized access, disclosure, alteration, or destruction.

In addition, CMS takes reasonable steps to maintain the accuracy of the information you provide to us. If you become aware of an inaccuracy in your personal information maintained by CMS, you may contact us at the email or postal address in this Privacy Policy.

What access does CMS give you to your personal information?

You may delete or update your personal information and email preferences, at any time.

You have the option of correcting, updating and/or changing contact and demographic information and other information previously provided and stored in our database. If you wish to correct, update or change your information, simply email: [email protected]. Alternatively, you may contact uat the following postal address:

Collaborative Marketing Solutions LLC
1150 First Avenue
Suite 501
King of Prussia, PA 19406

Your California Privacy Rights

As of January 1, 2005, California civil Code Section 1798.83 permits users of the Data360 website or services who are California residents to request certain information regarding the disclosure of personal information to third parties for such third parties’ direct marketing purposes. To make such a request, please contact CMS at the email or postal address above.

If you are a health care professional in the Data360 database and a California resident who wants to determine whether Data360 holds or sells information you’ve provided, in order to exercise any of your rights under the CCPA, then please contact us at: [email protected] and provide the following information:

  • Subject line: Data360 CCPA Request
  • Describe which CCPA right(s) you are exercising
  • Your full name
  • Your full address
  • Your telephone number where you can be reached to communicate with you regarding your CCPA request (if you prefer to communicate by phone)
  • Your email address as it pertains to your CCPA Request
  • Your email address where we can communicate with you regarding this CCPA request (if different from the email address described in the preceding bullet)
  • Describe manner in which you participated that engaged Data360 (e.g., online web survey, interview, written questionnaire, resource download, etc.)
  • Country of participation

You may be required to submit proof of your identity to make a request described above to Data360 to be processed as a verifiable consumer request. Data360 may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in connection with your request with personal information in our possession. You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization. Data360 will respond to your request pursuant to the requirements of the CCPA. The CCPA does not apply to certain information, including information made available from government records, certain data subject to the Health Information Portability and Accountability Act (HIPAA) and certain other laws, and where its application is preempted by, or in conflict with, Federal law, the United States Constitution, or the constitution of a state (as applicable).

European Union Data Protection Directive and Swiss Federal Act on Data Protection Safe Harbors:

Data360 adheres to the U.S. safe harbor privacy principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement with respect to both the European Union Data Protection Directive and the Swiss Federal Act on Data Protection, and is registered with the U.S. Department of Commerce’s Safe Harbor Programs for both. Information regarding the Safe Harbor Program can be found at the program’s website: http://export.gov/safeharbor/. If you have questions about our compliance with the safe harbor privacy principles, you may contact us at the email or postal address above.

Is This Privacy Policy Subject to Change?

Yes. The Data360 Privacy Policy is subject to change at any time.

By using our website and/or our services, you consent to the collection and use of this information by Data360 for the purposes disclosed in this Privacy Policy. If we decide to materially change our privacy practices, we will post a prominent notice of those changes on the Data360 website so that you are always kept informed of what data we collect, how we use it, and under what circumstances we disclose it. Please check our website for changes from time to time to make sure you are aware of our latest privacy practices.

Opt-Out Policy

If you would like to be removed, from the Data360 Database, please submit the following form: