MEDICX MEDIA SOLUTIONS
PRIVACY POLICY
Effective: December 22, 2016
Revised: February 15, 2020

SCOPE

Medicx Media Solutions (MMS) is an independent analytics driven marketing solutions company. Medicx utilizes a proprietary and patented Micro-Neighborhood® ZIP- based aggregation process (managed by a third-party data aggregator) to create HIPAA-certified (¹A re-identification risk determination assessment) ZIP based anonymous audience segments. The Medicx platform ingests de-identified offline ZIP level aggregated prescription and medical data (no actual claims level or patient level data) only, demographic data, and the ZIP of self-declared (affirmative expressed consent opt-in) health and lifestyle information collected from consumers and healthcare practitioners across the US. More than 35M+ Micro-Neighborhoods® are then profiled at the ZIP level with health data signals. The ZIP level data supports all digital and TV channels for targeted advertising.

MMS offers leading strategy, consulting, execution, analytics and measurement capabilities across all digital, advanced television, email, and direct response channels to reach its ZIP level audiences. MMS matches anonymized ZIP level health profiles within hyper-local areas to meet brands’ customized condition, insurance, and demographic-specific criteria. Using ZIP level target-initiated channel planning, MMS engages the custom-built ZIP Level audience segments across the most relevant channels to execute, optimize, and evaluate spend for clients with ROI as the singular focus.

We believe that use of our Micro-Neighborhood® ZIP database results in consumers seeing more ads relevant to their health interests without compromising their privacy. While our goal is to target ads as locally as possible, we do not accept or use any individual level health data. We take consumer privacy seriously and welcome this opportunity to explain the creation and use of the MMS Micro-Neighborhood® ZIP database and the privacy protections we have put in place.

This Policy covers the MMS Micro-Neighborhood® ZIP database and its use by MMS for digital, advanced television, email, and direct response channels to reach its ZIP level audiences.

INFORMATION WE COLLECT: HOW WE BUILD AND USE THE MICRO-NEIGHBORHOOD® ZIP DATABASE

The process of identifying hyper-local areas with a high prevalence of a given health condition begins with anonymized ZIP level health data derived from physician visits and dispensed pharmacy prescriptions, data recognized as Protected Health Information or “PHI” as that term is used in the Health Insurance Portability and Accountability Act of 1996, Pub. L. No. 104-191, the Health Information Technology for Economic and Clinical Health Act, Title XIII of Division A and Title IV of Division B of the American Recovery and Reinvestment Act of 2009 and analogous state laws. Third party data aggregators totally independent of MMS de-identify the physician visit and pharmacy data, re-associate the data using probabilistic and deterministic matching to aggregate into the postal ZIP’s from which they originated. Using ZIP level target-initiated channel planning, MMS engages the custom-built audience across the most relevant channels to execute, optimize, and evaluate spend for clients with ROI as the singular focus.

SERVING ADS TO HYPER-LOCAL AREAS

MMS uses common technologies and processes to reach consumers within a given hyper-local area from insights from our Micro-Neighborhood® ZIP database platform. We, or third-party vendors acting on our behalf, receive ranges of cookies, IP addresses, device ID’s or addressable tv subscriber households associated within a hyper-local area. MMS may rely on Healthy Offers Inc., www.healthyoffers.com, a separately maintained affiliate of MMS, as one source of IP addresses and cookies. MMS relies on third party cookies, IP addresses, and device ID’s to serve client ads to targeted hyper-local areas in which the ads may be most relevant. Our use of the cookies, IP addresses, and device ID’s does not identify individuals, track people across unaffiliated web sites or result in the compilation of a profile. For more information about controlling geotargeting cookies please see Your Choices www.aboutads.info/choices, below.

CONSUMER CHOICES

Consumers may use an opt out mechanism available from the Digital Advertising Alliance Consumer Choice Page, www.aboutads.info/choices, to turn off ZIP level targeting using third party cookies. Selecting The Trade Desk, Tube Mogul, and LiveRamp options will disable cookie-based targeting based on our ZIP level targeting database but please note that doing so may also disable use of The Trade Desk, Adobe (Tube Mogul), and LiveRamp cookies for other targeting that you may find useful. You may use controls available in most browsers to block or disable our third party or any other cookies.

OTHER IMPORTANT INFORMATION

PROTECTING CONSUMER PRIVACY

We take consumer privacy very seriously. Although MMS neither collects nor uses data about identifiable consumers or their individual related conditions or interests, we take a number of steps to strengthen privacy.

HIPAA Certification¹. MMS never receives personally identifiable health information or online behavioral data about individual health conditions or interests. Its Micro-Neighborhood® data, however, originate from “PHI” or Protected Health Data, covered by HIPAA. HIPAA’s Privacy Rule allows PHI to be used if the data is properly de-identified, that is, used in such a way that it cannot be connected back to the identifiable individual about whom it was generated. HIPAA also recognizes certification by qualified experts as one means to establish that the de-identification is complete and legally sufficient. MMS has obtained an expert certification that its receipt of de-identified health data, creation of the Micro-Neighborhood® Database and use in combination with a range of IP addresses, cookies, and device ID’s, and subscriber information for ad serving remains sufficiently de-identified to meet HIPAA requirements.  ¹ A re-identification risk determination was performed pursuant to the HIPAA Privacy Rule Expert Determination standard and the determination concluded that, in the given data use and disclosure context, the risk of re- identification was very small.

Recognition of Industry Self-Regulation. Health related data may be considered “sensitive” and may raise privacy concerns even if the data is not PHI and so, not regulated by HIPAA. Although MMS does not receive or collect any individually identified health data, MMS respects industry rules and best practices for online advertising and direct marketing. We maintain active memberships in several recognized industry self-regulatory organizations including the Interactive Advertising Bureau. MMS is also a registered participant in the Digital Advertising Alliance (DAA) and as noted above, consumers may use the DAA opt-out mechanism to block the third party ad serving cookies we use.

SECURITY

MMS maintains reasonable physical, technical and administrative safeguards to prevent unauthorized access, use, alteration or disclosure of all our data assets.

MMS SERVICES NOT COVERED BY THIS PRIVACY POLICY

MMS provides its clients a variety of other marketing services that do not rely on or use the Micro-Neighborhood® ZIP database and so are not covered by this Privacy Policy. In particular, Healthy Offers, Inc., of which MMS is a separately operated part, maintains a separate online lead generation platform, www.healthyoffers.com to allow its registered audience to choose to connect directly with pharma and health related clients. Please see the separate Healthy Offers Privacy Policy, https://www.healthyoffers.com/content/privacy-policy for information on how that platform may collect, use and transfer data that identifies you.

In addition, MMS may provide consulting, analytics, measurement and content related services for clients. We may also process personal data provided by clients for purposes of fulfillment or ad serving on the client’s behalf.

Changes to this Privacy Policy. We reserve the right to change the terms or scope of this Privacy Policy at any time. If the changes are material, we will so indicate at the beginning of the Policy.

ACCOUNTABILITY

Please contact Medicx Media Solutions directly at info@medicxmedia.com or at the address below if you have any questions about this Privacy Policy or the services described within it. Medicx Media Solutions is a separately operated part of Healthy Offers, Inc.

Medicx Media Solutions
Attn: Privacy Office
10799 North 90th Street, Suite 200
Scottsdale, AZ 85260