MEDICX MEDIA SOLUTIONS
Effective: December 22, 2016
Medicx Media Solutions (MMS or we) provides consumer insights, audience development and marketing services, including geotargeted ad serving, to clients in the health and pharmaceutical industries. Our ad targeting services rely on our proprietary Geotargeting Database – lists of geographic areas based on ZIP codes and the prevalence of given health conditions within each.
We believe that use of our 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 health data. We take consumer privacy seriously and welcome this opportunity to explain the creation and use of the MMS Geotargeting Database and the privacy protections we have put in place.
This Policy covers the MMS Geotargeting Database and its use by MMS for web-based, mobile and addressable TV advertising.
INFORMATION WE COLLECT: HOW WE BUILD AND USE THE GEOTARGETING DATABASE
The process of identifying neighborhoods with a high prevalence of a given health condition begins with individual health data from physician visit and pharmacy insurance claims, 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. Data vendors 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 ZIP codes from which they originated and then use aggregated data to indicate the prevalence of given health related condition within each ZIP-based area. A list of ZIP codes indicating conditions as used by MMS’s client base as a whole is then delivered to MMS. We use a proprietary method to calculate the likelihood of a given condition in each neighborhood then extract lists of ZIP-based neighborhoods that demonstrate a high prevalence of that condition.
Serving Ads to ZIP-based Neighborhoods.
MMS uses common Internet technologies and processes to reach consumers within a given neighborhood. We, or third party vendors acting on our behalf, receive ranges of cookies associated with a ZIP-based neighborhood, IP addresses associated with a ZIP-based neighborhood or lists of device ID’s known to use the Internet from those neighborhoods. 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 neighborhoods 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.
We may also use the lists of ZIP codes we pull from the Geotargeting Database to conduct a statistical analysis of the success of a particular online ad campaign. To do so, MMS commissions a third party to analyze the aggregate changes, if any, in the purchase of a given advertised pharmaceutical or health product within the geotargeted area in which online ads were served. The analysis necessarily requires MMS to send a copy of the ZIP lists of targeted areas to the third party to conduct its analysis.
USE OF THE GEOTARGETING LISTS BY THIRD PARTIES
MMS licenses its geotargeting lists to third party service providers for ultimate use to reach relevant neighborhoods through addressable TV advertising. We may also, on occasion, license our lists to clients for their basic research and analytics purposes with contractual limits on use of the lists to prohibit re-identification of individuals.
Consumers may use an opt out mechanism available from the Digital Advertising Alliance Consumer Choice Page, www.aboutads.info/choices, to turn off geotargeting using third party cookies. Selecting The Trade Desk, Tube Mogul, and LiveRamp options will disable cookie-based targeting based on our Geotargeting Database but please note that doing so may also disable use of The Trade Desk, 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 Certification. MMS never receives personally identifiable information or online behavioral data about individual health conditions or interests. Its geotargeting lists, 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 Geotargeting 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.
- 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 Direct Marketing Association and the Interactive Advertising Bureau. MMS is registered with the Digital Marketing Alliance and as noted above, consumers may use the DAA opt out mechanism to block the third party ad serving cookies we use.
MMS maintains reasonable physical, technical and administrative safeguards to prevent unauthorized access, use, alteration or disclosure of all our data assets.
In addition, MMS may provide consulting and content related services for clients. We also process personal data provided by clients for purposes of fulfillment or ad serving on the client’s behalf.
Medicx Media Solutions
10799 North 90th Street, Suite 200
Scottsdale, AZ 85260