MEDICX MEDIA SOLUTIONS
PRIVACY POLICY
Effective: December 22, 2016
Revised: May 12, 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 pseudonymized audience segments. The Medicx platform ingests pseudonymized offline ZIP level aggregated prescription and medical data (no actual claims level or patient level data) only.

Medicx also utilizes demographic data, and the ZIP of self-declared consumers (affirmative expressed consent opt-in) who disclose their health and lifestyle information and grant Medicx permission to use and share their information in exchange for receiving valuable information and offers form our clients. In addition, Medicx collects data from self-declared healthcare practitioner across the US.

More than 35M+ Micro-Neighborhoods® are profiled at the ZIP level with health and lifestyle signals to build customized audience targets. The ZIP level data supports all channels for hyperlocal targeted advertising.

MMS offers leading strategy, consulting, execution, analytics and measurement capabilities across all digital, advanced television, streaming services, email, and direct response channels to reach its ZIP level audiences. MMS matches pseudonymized 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 pseudonymized 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® pseudonymized ZIP database and the privacy protections we have put in place.

This Policy covers the MMS Micro-Neighborhood® pseudonymized ZIP database and its use by MMS for digital, advanced television, streaming services, email, and direct response channels to reach its pseudonymized 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 pseudonymized ZIP level health data derived from physician office 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 pseudonymize 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 safe harbor vendors, acting on our behalf, receive ranges of cookies, IP addresses, device ID’s, email addresses or advanced television/streaming services subscriber households associated within a hyper-local area. MMS relies on third party cookies, IP addresses, device ID’s or advanced television/streaming services subscriber household information to serve client ads to targeted hyper-local areas in which the ads may be most relevant. Our use of the cookies, IP addresses, device ID’s or advanced television or streaming services and subscriber household information does not identify individuals, track people across unaffiliated web sites or result in the compilation of a profile. For more information about controlling how you may receive client ads. Please see section on Consumer Choices for the specific media channel.

CONSUMER CHOICES

Medicx works with third party vendors and partners that work on our behalf that honor consumer choices for advertising.  These third parties provide ways for consumers to opt out of receiving advertisements through the consumer’s cookies, IP addresses, device ID’s or advanced television/streaming services subscriber households as applicable.  Below is a summary of these opt out mechanisms that may not only disable MMS but other targeting connects:

Advanced Television and Streaming Services:  Individuals may opt out on their streaming services by using the streaming service’s operation system settings and for addressable television directly through your cable or satellite provider.

Digital Advertising:  Individuals may also use their browser and device settings to stop cookies and the usage of device information for personalized advertising using one or more of the following mechanisms:

  • Digital Advertising Alliance Consumer Choice Page, aboutads.info/choices, Selecting The Trade Desk and LiveRamp options will disable cookie-based targeting based on our pseudonymized ZIP level targeting database but please note that doing so may also disable use of The Trade Desk 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.
  • LiveRamp, https://liveramp.com/opt_out/, will disable cookie and device ID based targeting on our pseudonymized ZIP level targeting database.
  • The Trade Desk, http://www.adsrvr.org, will disable cookie and device id based targeting on our pseudonymized ZIP level targeting database.

Direct Mail:  Individuals may opt-out through https://medicxmedia.com/email-direct-mail-opt-out.

Email:  Individuals may opt-out through https://medicxmedia.com/email-direct-mail-opt-out.

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 pseudonymized 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 pseudonymized 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.  Conducted every 18-24 months to ensure data and associated processes cannot result in patient re-identification.

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, as one way 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.

DATA & DATA RETENTION

Medicx obtains campaign performance data that is used for internal purposes to improve performance of advertising, marketing and the effectiveness of Medicx services and business offerings.  Medicx may use campaign data to detect and eliminate fraud, to provide, improve, test, and monitor and to generate and provide aggregate statistics about the performance of the Medicx services. Medicx does not identify particular individuals using this information.

Medicx retains pseudonymous data for up to 24 months. After 24 months (if not sooner) the data is aggregated and stored for up to 3 additional years if necessary in order to provide our Services and valid contractual or legal obligations.

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 pseudonymized 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 privacy@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
Email: privacy@medicxmedia.com