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: Email, 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.
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?
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.
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.
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.
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.
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.
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
1201 N. Market St.
Wilmington, DE 19801
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.
If you would like to be removed, from the Data360 Database, please submit the following form: