Adfire Health LLC- Online Privacy Policy

Effective Date: 8/4/2020
Please read our privacy policy in its entirety, and don’t hesitate to reach out to us at privacy@adfirehealth.com if you have any questions.
​​Katon Partners LLC dba Adfire Health (“Adfire Health”, “We”, “Us”) respects the privacy rights of our users and is committed to protecting the information collected on our website and the information we use to provide services to our clients. This privacy policy (“Privacy Policy”) explains:
By accessing, registering for, or otherwise using any of the products or services offered by Adfire Health, you agree to this Privacy Policy and give your consent to the collection, use, and processing of personal information in accordance with this policy. If you do not agree to this Privacy Policy, please do not access, register for, or use any of the Adfire Health Services (as defined below).

Adfire Health’s Services

Adfire Health provides hyper-targeted, personalized and creative digital advertising experiences to our advertising clients (“Clients”) by merging clean and accurate data with creativity, programmatic technology and marketing expertise (the “Client Services”). Our Client Services specialize in the healthcare industry by targeting healthcare professionals and patients (“Users”). Adfire Health also owns and operates this website (www.adfirehealth.com) (“Website”) and owns or licenses the related content, information, materials, products, and services available through the Website (collectively, the “Website Services”). This Policy refers to the Client Services and the Website Services together as the “Adfire Health Services” or the “Services.”
Behind our operations and communications is a compassionate team of professionals who genuinely care about delivering healthcare marketing services. Adfire Health adheres to the National Advertising Institute’s (NAI) Code of Conduct. We provide this Privacy Policy because we want you to understand the information we collect about you, how we use it, how we share it, and how you can control your information.

SECTION I: THE SOURCES AND TYPES OF PERSONAL INFORMATION WE COLLECT

The Adfire Health Services collect information that may personally identify an individual or have the potential to personally identify an individual (“Personal Information”). This section explains the sources and types of Personal Information we have or may collect from the Client Services and the Website Services.

CLIENT SERVICES INFORMATION

Adfire Health collects data from multiple sources to build a first party proprietary database of healthcare provider and patient data (“User Data”) that we use to provide the Client Services to our advertising Clients. This database helps us deliver the right ads to the right online Users, improving Users’ searches for great products and solutions and increasing the effectiveness of our Clients’ online marketing campaigns. Below, we explain the categories of Personal Information we may have collected from Users and the sources of that information.
Data from our DSP

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).
Data from our Affiliates
Katon Partners LLC dba Katon Direct (“Katon Direct”) licenses its first-party database of healthcare professional information to Adfire Health. The data that Adfire Health licenses from Katon Direct includes a healthcare provider’s email address and NPI number. We link this information and add it to other User Data we have about Users, such as cookie identifiers and associated segment, or HCP specialty.
Data from Third Parties

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
Data from Public Sources
We may obtain data from public records or other publicly available information, such as National Provider Identifier (NPI) records that include a healthcare provider’s name, specialty, and practice address. We may link and add this publicly available information to other Personal Information in our User Data.

CLIENT SERVICES INFORMATION

Data from Website Services

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.
Data from Third Parties
If Adfire Health partners with a third party to provide products or services to you, the third party partner may share the Personal Information it has collected about you with us, and we may link that information with our Website Services Data. The Personal Information collected by a third-party partner will be subject to the third-party partner’s privacy policy, and you should refer to the third-party partner’s policies to exercise your data rights over that Personal Information. You may refuse to provide, or request that we delete, certain categories of Personal Information we have about you. However, if our collection of the Personal Information is required by law or contract or is necessary for you to access or use any of the Services, we may be unable to provide the Services to you.

SECTION II: HOW WE USE PERSONAL INFORMATION

User Data
We use User Data for the following purposes:
  • 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.
Website Services Data

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 fulfill our contractual obligations to our Clients. We use your Personal Information to process your transactions and payments, fulfill our obligations under a contract (including our Terms of Use), send you order confirmations or account updates, and to respond to your requests and for any related communications.
  • 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.
  • To provide our Services. We may share your information with third-party service providers and agents who provide or perform services on our behalf to help with our business activities, such as ad technology providers, payment processors, email service providers, data analyzers, and business intelligence providers for the purpose of enhancing our products and services. We also use third-party service providers to help us protect the security of our networks or store and/or manage our data and databases. These service providers are authorized to use Personal Information only as necessary to provide these services to us, and we require these service providers to agree to privacy and security measures consistent with this Privacy Policy. These third parties currently may include: Throtle and other third parties.
  • 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

Opt-out from Adfire Health’s Marketing Products
You may opt-out from our direct marketing products by emailing privacy@adfirehealth.com. If you do not exercise your opt-out preference initially upon account creation, it may take up to thirty (30) days for your opt-out choices to be fully effective. Unless prohibited by applicable law, your opt-out preference does not apply to (i) any communication which is not promotional in nature or (ii) sharing with service providers and use by us of your Personal Information to provide or improve the Services.
Opt-out of Interest-Based Advertising
We adhere to self-regulatory principles under the Network Advertising Initiative (NAI) for interest-based advertising. Additional information on the NAI and its code can be viewed at http://www.networkadvertising.org/code-enforcement/code. To opt out of Adfire Health’s interest-based advertising, please visit www.optout.networkadvertising.org. To opt out of all personalized advertising created by Cross-Device Mapping, you will need to perform an opt-out on each browser or device you want to unlink.
Browser Cookies
Most browsers will allow you to accept, refuse and delete cookies by adjusting your browser settings. Please note that if you set your browser to reject cookies, we may be unable to provide you with the Services, or the Services may not function optimally. To find out more information, you can visit www.allaboutcookies.org.
Mobile Identifiers

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.

California residents may have additional rights under the California Consumer Privacy Act (“CCPA”). If you are a California resident, please refer to the California Privacy Notice at the end of this Privacy Policy.

DATA RETENTION
We retain Personal Information according to applicable laws or regulatory requirements and keep it as long as is necessary to fulfill the purposes described in this Privacy Policy or for which the personal data was collected.

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.
DATA SECURITY
The security of Personal Information is important to us. We follow generally accepted standards to protect the Personal Information we control, both during transmission and once it is received, and take various precautions to protect information from loss and misuse. For example, we limit access to information to employees, contractors and agents who need to know this information in order to perform services for us and who are contractually obligated to comply with confidentiality obligations consistent with this Privacy Policy. However, no method of transmission or storage of information can ever be completely secure. Also, please also remember that we are not responsible for the security measures of third parties. If you have any questions about the security of your Personal Information, please contact us at privacy@adfirehealth.com.
THIRD PARTY LINKS
We may provide content or information on the Website or other Services that links or refers to third-party sites or services. For example, we may post links to our social media profiles so you can find us easily. We do not control, and are not responsible for, third parties’ privacy practices and content. When you click on a link to a third-party site or service, the third party may collect personal information, which will be governed by the third party’s privacy policy. Please read the third party’s privacy policy to learn about how they collect and process personal information.
COOKIES

Adfire Health and its partners use cookies or similar technologies to analyze trends, administer the Website, track users’ movements around websites, and to gather demographic information about our user base as a whole. 

Cookies” are small text files that are stored in a computer’s web browser memory. They help us recognize your device and remember your preferences, such as your login details or shopping cart contents, improve your user experience, and remember whether you consented to our cookies. We use the term “cookie” throughout this Privacy Policy to describe several technologies, including:

  • 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.

How We Use Cookies

We or our service providers acting on our behalf use cookies for the following purposes:

  • 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.
Managing Cookies
Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. You can withdraw or modify your consent to our use of cookies at any time. Your web browser’s settings will allow you to accept, refuse and delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Note that if you set your browser to refuse cookies, you may not be able to use all the features of the Services. For more information, please visit www.allaboutcookies.org.
CHILDREN’S PRIVACY
We do not knowingly collect, disclose, or sell the Personal Information of children under the age of 18. If you are a parent or guardian and believe we have collected information about a child, please contact us using the Contact Information provided in this Privacy Policy. We will take steps to delete the information as soon as possible.
DO NOT TRACK
We are committed to providing you with meaningful choices about the information we collect on the Services, and that is why we provide the opt-out choices set forth in this Privacy Policy. However, we do not recognize or respond to browser-initiated Do Not Track (“DNT”) signals, in part because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators, nor is there a consistent standard of interpreting user intent.
CHANGES TO THIS POLICY
We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices
WEBSITE LOCATION, US TRANSFER & PROCESSING
THE SERVICES ARE OPERATED BY ADFIRE HEALTH IN THE UNITED STATES, AND PERSONAL INFORMATION WILL BE PRIMARILY STORED IN THE UNITED STATES. BY PROVIDING PERSONAL INFORMATION TO US, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, YOU ACKNOWLEDGE THAT WE COLLECT, MAINTAIN, PROCESS AND TRANSFER SUCH INFORMATION IN AND TO THE UNITED STATES AND OTHER COUNTRIES AND TERRITORIES, PURSUANT TO THE LAWS OF THE UNITED STATES OR SUCH OTHER JURISDICTIONS, WHICH MAY PROVIDE LESSER PRIVACY PROTECTIONS THAN EUROPEAN ECONOMIC AREA COUNTRIES, AND TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, YOU ACKNOWLEDGE THAT YOUR INFORMATION MAY THUS BE SUBJECT TO U.S. FEDERAL AND CALIFORNIA STATE LAW AND OTHER FOREIGN LAWS AND ACCESSIBLE TO U.S. AND FOREIGN GOVERNMENTS, COURTS, LAW ENFORCEMENT AND REGULATORY AGENCIES.

Contact Us

Adfire Health

2 Landmark Sq. Suite 214

Stamford, CT 06901

Telephone Number: (+1) (914) 921-8800

E-mail address: privacy@adfirehealth.com

CALIFORNIA PRIVACY NOTICE
This California Privacy Rights Notice (“Notice”) applies only to individuals residing in the State of California who are considered “consumers” and from whom we collect “personal information” as those terms are defined in the California Consumer Privacy Act of 2018 (“CCPA”). We will update this Notice at least once every twelve (12) months to reflect changes in our business, legal or regulatory obligations, so please check this Notice periodically for changes.
How We Collect, Use, and Disclose Your Data

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
  • Identifiers
  • Internet or Other Electronic Network Activity Information
  • Geolocation Information
  • Commercial Information
  • Payment Information
  • Professional or Employment Information
Your CCPA Rights and Choices
California consumers have the following rights regarding our use and disclosure of your personal information, subject to certain limitations in the CCPA:
  • 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.
You may exercise any of the rights above by submitting a request using the Contact Information provided above. We may need to verify your identity before responding to your request, such as by requesting government-issued identification or confirming your full name, email address or account access.
Authorized Agents
You may authorize someone to act as your agent and submit a CCPA request on your behalf. Before we will respond to any such request: (1) we require your agent to provide us with written evidence of permission to act on your behalf, and (2) you must verify your identity directly with us, unless your authorized agent is acting pursuant to a power of attorney under the California Probate Code.
Shine the Light Law (Cal. Civ. Code § 1798.83)
We only share the Personal Information of California residents with third parties for direct marketing purposes if we obtain your opt-in consent, or you are offered the opportunity to opt-out and elect not to opt-out of such sharing at the time you provide Personal Information. If you do not provide opt-in consent or if you opt-out, we will not share your Personal Information with third parties for direct marketing purposes.

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