Adfire Health’s Services
SECTION I: THE SOURCES AND TYPES OF PERSONAL INFORMATION WE COLLECT
CLIENT SERVICES INFORMATION
Adfire Health collects Personal Information on online Users passed to us by our demand-side platform partner (DSP). A DSP generally works with multiple buyers to facilitate the purchase of online advertising space from publishers. DSPs share certain data about publishers and their available ad spaces with us so that we are able to evaluate whether to bid on an opportunity to show an ad to a User. Our DSP may provide us with the following Personal Information:
- Unique Cookie IDs or other IDs;
- referrer URL;
- how a User engaged with the advertisement (e.g., click or impression).
Adfire Health licenses certain data from third parties, such as data brokers, for ad targeting purposes. In any instance where Adfire Health utilizes third-party data, Adfire Health performs the necessary due diligence to determine that the third-party data providers are reliable. Data we license from third parties is linked and added to User Data, and includes the following:
- Cookie identifiers
- IP address
- Advertising identifiers
CLIENT SERVICES INFORMATION
When you visit the Website, register or purchase any products or services from us, send us communications, or respond to surveys or promotional offers, we may collect the following Personal Information (“Website Services Data”):
- Identifiers: We may collect your full name, email address, physical address, phone number, IP Address, device ID, cookie ID, or other similar identifiers. We may also collect any other Personal Information that you provide to us, such as social media identifiers, language preference, or website URL.
- Internet or Other Electronic Network Activity Information: We may collect information regarding your interaction with the Services, including time of visit and geolocation data, pages visited, links clicked, emails opened, language preferences, and the pages that led or referred you to our Services. We may also collect information automatically from your device, such as device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, and add-ons.
- Geolocation Data: We may collect your physical location or infer your physical location based on your IP address, mailing address, or other network or voluntarily provided information.
- Commercial Information: We may collect information about the products or services you have purchased, obtained, or considered from us or our partners.
- Payment Information: In order to process your orders, we collect credit card information or other payment information.
- Professional or Employment-related Information: We may collect job-related information from you, such as your title, manager, company, or website. You provide this information through your voluntary communications with us, by providing contact or payment information (such as your email address or company credit card), or by responding to an email, newsletter, or survey.
SECTION II: HOW WE USE PERSONAL INFORMATION
- Interest-based advertising: User Data helps us infer what may interest you and serve you ads based on those presumed interests. The types of data Adfire Health relies on for these activities include standard header data and data stored in cookies and non-cookie technologies. Data is retained for a year and then archived for reporting purposes.
- Geographic targeting: We use User Data to customize the ads shown to you based on your current or previous location.
- Advertising metrics: We use User Data to help us determine how and whether you interacted with an advertisement (for example, by viewing it or clicking on it).
- Cross-Device Mapping: We use User Data for cross-device mapping to serve or measure advertising on related devices on behalf of our clients. Specifically, Adfire Health may collect identifiers, such as cookies, IDFA, and Google AdID, directly from your browser or mobile applications.
- Retargeting: We use your information to allow us or third parties to deliver ads based on your interests on our sites, affiliated sites, or third-party sites. Our retargeting activities abide by the NAI Code of Conduct.
We use Website Services Data: (1) with your consent for the reasons that you provide such information, and (2) for the purposes set forth below:
- For our legitimate business interests. We use Website Services Data to provide or enhance our services to our Clients; compile statistics on advertising transactions made through the Adfire Health Services; perform research and development for our own internal business needs; analyze and report on campaign and ad performance; market and promote the use of our Services; and examine, prevent and discourage malicious activity, false traffic or fraudulent, unauthorized or illegal activity on or through the Services. If we use Personal Information for marketing purposes, we will only contact you for direct marketing purposes in accordance with applicable laws. You may opt-out of our use of your Personal Information for marketing, market research, or direct marketing purposes at any time by sending a right request as set forth in SECTION IV: YOUR RIGHTS AND CHOICES.
- To comply with a legal obligation or requirement. We use and process your Personal Information when we believe doing so is necessary to comply with laws and regulations, pursuant to a judicial authorization, or to exercise or defend our legal rights or those of a third party.
SECTION III: HOW WE SHARE AND DISCLOSE PERSONAL INFORMATION
Adfire Health shares or discloses Personal Information for the following business purposes:
- With your consent. We may request to share Personal Information, such as identifiers (including individual email addresses) with third-party business partners so that we can provide you with information about their products.
- Third-party marketing. We provide our clients (advertisers) with reports about the types of users seeing their ads and how their ads are performing, including information such as a healthcare provider’s NPI number, name, or email address.
- To comply with legal requirements. We may access, preserve and disclose Personal Information to government agencies, law enforcement, regulatory bodies, or other third parties in response to a legal request and if we have a good faith belief that the law requires us to do so.
- To protect us or others. We may access, preserve and disclose information with third parties when we have a good faith belief it is necessary to detect, prevent and address fraud and other illegal activity; to protect ourselves, you, and others, including as part of investigations; or to prevent death or imminent bodily harm.
- As aggregate information. We may disclose non-personally identifying, aggregated information about the Services.
- As a result of merger or sale of our business. If we are a party to a merger, consolidation, sale of assets, bankruptcy, or other business restructuring, we may disclose Personal Information to a successor entity.
SECTION IV: YOUR RIGHTS AND CHOICES OVER YOUR INFORMATION
Your mobile device’s operating system may provide you with additional options to opt out of interest-based advertising or to control your device’s mobile identifiers. For example, iOS devices have a “Limit Ad Tracking” setting, and Android devices have a “Opt out of Interest-Based Ads” setting, which allow you to control the information used to target ads based on your interests. Please refer to your mobile device’s settings for more information.
When Clients receive Personal Information through us, their storage and retention of the Personal Information is governed by their own privacy policies and by applicable laws, rules, or regulations.
- pixel tags (transparent graphic images placed on a web page or in an email, which indicate that a page or email has been viewed),
- mobile device identifiers, and
- web storage used in desktop software or mobile devices.
Cookies can stay on your device for varying amounts of time, depending on whether they are session cookies or persistent cookies. Session cookies expire once you close your web browser. Persistent cookies stay on your device until their expiration date, which varies depending on a cookie’s setting, or until you delete them.
- Necessary Cookies: We use these cookies to operate the Services, authenticate you and keep you logged in, and to monitor use of the Services to detect fraud or other harmful or illegal activities on the Services.
- Preferences Cookies: These cookies help us remember your preferences, including remembering your username and your setting or profile configurations.
- Statistics/Performance / Analytics Cookies: We use these cookies and other similar technologies to analyze how you access or use the Services, and how the Services are performing. We may also use these cookies to obtain information from our email campaigns or other communications we send to you, including whether you opened or forwarded an email or clicked on any of its content.
- Marketing Cookies: These cookies track you across the Internet and help third party advertisers and publishers display ads that are relevant to you. To the extent permitted by applicable law and with your consent, we may permit third parties to gather Personal Information passively on our websites for behavioral or interest-based advertising and re-targeting.
In the last 12 months, we have collected the categories of Personal Information from the categories of sources listed in Section I above. We have used those categories of Personal Information for the business or commercial purposes specified in Section II above. We may have disclosed or sold, to the categories of third parties listed in Section III above, the following categories of Personal Information:
- User Data
- Website Services Data
- Internet or Other Electronic Network Activity Information
- Geolocation Information
- Commercial Information
- Payment Information
- Professional or Employment Information
- The right to know. You may request, up to twice in a 12-month period, the following information about the Personal Information we have collected about you during the past 12 months:
- the categories of Personal Information we have collected about you;
- the categories of sources from which we collected the Personal Information;
- the business or commercial purpose(s) for collecting the Personal Information;
- the categories of third parties with whom we shared the Personal Information;
- the categories of Personal Information we have sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information
- The right to delete. You may request that we delete the Personal Information we have collected about you, subject to certain limitations under applicable law. We may not delete all of your Personal Information if one of the following exceptions applies:
- To complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or perform a contract we have with you;
- To detect data security incidents;
- To debug or repair any errors;
- To protect against fraud or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; or
- To use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e. to improve our services).
- The right to opt-out from a sale. You may opt out of any “sale” of your Personal Information by clicking on the Do Not Sell My Information link in the footer of every page of our Website. California law broadly defines what constitutes a “sale” – including making available a wide variety of information in exchange for “valuable consideration,” which is not limited to “monetary consideration.” Depending on what information we have about you, and whether we have included any of it in our products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in Section III.
- The right to non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.