Privacy Policy
Last updated January 24, 2020
This Privacy Policy describes the treatment of information provided or collected on Tandem websites where it is posted. Know that in addition to this website, Tandem maintains a series of other sites under various proprietary titles created to support client marketing campaigns. These are collectively referred to as “microsites” throughout this document. This Privacy Policy links to those microsites and is applicable to all microsites as well as mobile versions of all Tandem controlled websites where this Privacy Policy is posted.
About Tandem, Our Marketing Practices, and an Overview of How We Collect and Use Personal Information
As an omnichannel marketer focused exclusively on Healthcare Professionals (HCPs), Tandem communicates with HCPs through a variety of marketing channels. We collect personal information that specifically identifies an individual (such as a name or email address) through an opt-in process whereas to include HCPs in promotional efforts. We may also acquire personal information, or have it provided by a Client, from third party sources which include personal information on overall prescribing behavior, opted-in email addresses, professional demographic data, medical claims data, lab testing, and other similar data sets.
Through the execution of our marketing campaigns, we collect promotional response data which includes, but isn’t limited to, email deliverability, email open and click rates, direct mail response rates, website browsing activity within our controlled microsites, targeted print and digital advertising, and other usage and device/location information. As data is collected directly, passively, or via third parties, Tandem combines this data to create a profile of overall promotional responsiveness at both individual and aggregate levels. We use this information to improve our products, services, and to help inform what we communicate. These profiles also help us customize your experience and deliver more meaningful content.
We will provide both aggregate and personally identifiable promotional response data to our Client sponsors and their approved suppliers as part of our overall marketing services.
While Tandem does sell this information to our Clients as part of a specific campaign, we do not sell access to our entire database of personal information as a stand-alone service.
If you are a California consumer and would like information about our online and offline privacy practices and your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement.”
Information We Collect and How We Collect It
We develop marketing campaigns for companies working in the healthcare sector and execute direct promotion to HCPs. We generally collect demographic data, including name, business address, and email address. In select instances, we may collect and store information such as age and gender. We collect this information through the purchase of data via select partners as well as through our registration process. We do not collect, store, or share what is generally considered “sensitive” personal information such as income, social security numbers, credit card or bank information, etc.
In addition to the promotional response data collection procedures indicated above, if you visit any of our owned websites, we collect information about the browser you are using, your source of entry to the website, and what pages you visit. We will also collect information regarding your location as identified by your IP address/provider.
We collect this information using tracking tools like browser cookies, web beacons, embedded tracking pixels, and other standard tracking methods. From time to time, we get information about you from third parties. For example, our business partners may give us information about you. Social media platforms may also give us information about you.
We may use Google Analytics, which is a web analytics service provided by Google, Inc. Google and similar services to collect certain information relating to your use of the website. Such services may use cookies to help the website analyze how users use the website. You can find out more about how Google uses data when you visit our website by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/).
We use information for security purposes. We may use your information to protect our company and our customers. We also use information to protect our websites and platforms.
We use your information as otherwise permitted by law or as we may notify you.
Sharing Your Information With Other Entities
We share information with third parties who perform services on our behalf. For example, we share information with vendors who send emails, manage website, distribute postal mail, facilitate online ad targeting, or process payments for us. When companies perform services on our behalf, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law.
We will share information with our business partners. For example, we may share your information with our clients or their business partners who sponsor our marketing programs. The data we share is generally limited to promotional response data indicated above. Based on this promotional response data, our clients or their business partners may send you additional communications. Please note that once we share your personal information, the information received by the client or business partners is controlled by that company and becomes subject to the other company’s privacy practices.
We will share information in order to comply with the law or to protect ourselves. For example, we will share information to respond to a court order or subpoena. We may share it if a government agency or investigatory body requests it. We might share information if we are investigating potential fraud.
If our business or part of our business is sold, we reserve the right to include customer lists and historical promotional response data as part of that transaction.
You have certain choices about how we use your information.
We provide you with the ability to exercise certain controls and choices regarding our collection, use, and sharing of your information in accordance with applicable State and Federal laws.
You can opt out of receiving our marketing communications. To stop, email us at [email protected] or follow the instructions in any promotional email message you receive from us. Even if you opt out of getting marketing messages, occasionally we may still send transactional communications. These include responses to your questions or other necessary communications. In addition, opting out of future communications does not mean that Tandem will remove past historical promotional response data at the individual or aggregate levels.
You can control the types of targeting advertising you receive from many ad networks and partners, data exchanges, and marketing analytics and digital advertising and marketing service providers. You can control this by visiting the Digital Advertising Alliance WebChoices Tool (http://www.aboutads.info/choices). We and our digital display partners adhere to Ad Choices.
Interest-Based Advertising
We believe that advertising is more effective and relevant when it is targeted to your interests and behaviors. Therefore, we and third parties with whom we work may collect information on our website, through our emails and elsewhere through the use of cookies and similar methods, and we may use and disclose such information, in order to serve you with relevant advertisements on other services or to determine that you have seen our advertisements on other services. You do have the ability to control certain advertising practices. We comply with the Self-Regulatory Principles for Online Behavioral Advertising as administered by the Digital Advertising Alliance (DAA). You can learn more about interest-based advertising and opt-out of targeted advertising from certain providers with whom we work by visiting the DAA’s consumer choice page. The opt-out process through the DAA relies upon the placement of an opt-out cookie on your device. We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms automatically transmitted by web browsers for which we cannot evaluate your choice. For targeted advertisements delivered through mobile Apps, you can install the DAA’s AppChoices app on your device to opt-out of targeted advertising by certain providers and can also select a system level advertising preference feature on your device (such as “Limit Ad Tracking” on Apple devices).
California Consumer Privacy Statement
This section applies solely to California consumers. This section provides information about our online and offline privacy practices. This Statement does not apply to our personnel.
This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).
1. Notice of Collection and Use of Personal Information
We may collect the following categories of personal information about you:
Identifiers: identifiers such as a real name, business postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, National Prescriber Identifier, American Medical Association ID, and other similar identifiers
Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
Employment Information: professional or employment-related information, including affiliations to hospitals, IDNs, ACOs, or group practices
Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
We may use the categories of personal information listed above for the purposes described in our Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:
Purposes
Categories of Personal Information
Performing services providing customer service, verifying customer information, providing advertising or marketing services, providing analytics services, providing personal information to our clients, personalization and customization of marketing messaging, or providing similar services
Identifiers; Online Activity; Geolocation Data; Employment Information; and Inferences
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, email deliverability, email open rates, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
Identifiers; Online Activity; Geolocation Data; Employment Information; and Inferences
Professional contact information, demographic data, historical promotional response data, prescribing data, medical claims data, and Sunshine Act reporting data
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
Identifiers; Online Activity; Geolocation Data; Employment Information; and Inferences
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
Identifiers; Online Activity; Geolocation Data; Employment Information; and Inferences
Debugging to identify and repair errors that impair existing intended functionality
Identifiers; Online Activity; Geolocation Data; Employment Information; and Inferences
Undertaking internal research for technological development and demonstration
Identifiers; Online Activity; Geolocation Data; Employment Information; and Inferences
In addition, we may also use the following categories of personal information for purposes of managing our career opportunities: Employment Information; Education Information and Inferences
2. Our Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.
a. Sources of Personal Information
We may have obtained personal information about you from various sources, as described below.
Categories of Sources of Data Collection
Categories of Personal Information
Directly from you, such as when you contact us
Identifiers; Online Activity; Geolocation Data; Employment Information; and Inferences
From your devices, such as when you visit our website
Identifiers; Online Activity; Geolocation Data; Employment Information; and Inferences
Our affiliates and subsidiaries
Identifiers; Online Activity; Geolocation Data; Employment Information; and Inferences
Vendors who provide services on our behalf
Identifiers; Online Activity; Geolocation Data; Employment Information; and Inferences
Social networks
Identifiers; Online Activity; Geolocation Data; Employment Information; Education Information and Inferences
Online advertising companies
Identifiers; Online Activity; Geolocation Data; Employment Information; Education Information and Inferences
Government entities
Identifiers; Online Activity; Geolocation Data; Employment Information; Education Information and Inferences
Consumer data resellers
Identifiers; Online Activity; Geolocation Data; Employment Information; Education Information and Inferences
b. Sharing of Personal Information
We may have shared your personal information with certain categories of third parties, as described below.
Categories of Third Parties
Categories of Personal Information
Our affiliates and subsidiaries
Identifiers; Demographic Data; Promotional Response Activity; and Geolocation Data
Vendors who provide services on our behalf
Identifiers; Demographic Data, Promotional Response Activity; and Geolocation Data
Our affiliates and subsidiaries
Identifiers; Online Activity; Geolocation Data; Employment Information; and Inferences
Professional services organizations, such as auditors and law firms
Identifiers; Online Activity; Geolocation Data; Employment Information; Education Information and Inferences
Our joint marketing partners
Identifiers; Demographic Data; Promotional Response Activity; and Geolocation Data
Our business partners
Identifiers; Demographic Data; Promotional Response Activity; Geolocation Data; Employment Information; Education Information and Inferences
Advertising networks
Identifiers; Demographic Data; Online Activity; Geolocation Data; Employment Information; Education Information and Inferences
Internet service providers
Identifiers; Online Activity; Geolocation Data; Employment Information; and Inferences
Data analytics providers
Identifiers; Demographic Data; Promotional Response Activity; and Geolocation Data
Operating systems and platforms
Identifiers; Demographic Data; Online Activity; Promotional Response Activity; and Geolocation Data
Social networks
Identifiers; Demographic Data; Online Activity; Geolocation Data; Employment Information; Education Information and Inferences
c. Sale of Personal Information
As part of our contractual agreements with our Clients, we may provide them or their third party partners with personal information about you and how you interacted with the marketing materials we sent. This would constitute the sale of your personal information, as defined under the CCPA, to our clients and other third parties as described in this Privacy Policy. You have the right to opt out of this disclosure of your information, as detailed below.
During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may have sold the following categories of personal information:
Identifiers: identifiers such as a real name, business postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, National Prescriber Identifier, American Medical Association ID, and other similar identifiers
Internet and other electronic network activity information, including, but not limited to, browsing history, search history, email deliverability, email opens, and information regarding your interaction with websites, applications or advertisements
Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.
d. Disclosure of Personal Information for a Business Purpose
We may have disclosed to third parties the following categories of personal information for a business purpose:
Identifiers: identifiers such as a real name, business postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, National Prescriber Identifier, American Medical Association ID, and other similar identifiers
Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
Geolocation Data
Professional or employment-related information
Education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
3. California Consumer Privacy Rights
You have certain choices regarding our use and disclosure of your personal information, as described below.
Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
Shine the Light Request: You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties.
How to Submit a Request: To exercise the access, deletion and opt-out rights described above, please submit a request to us by either:
Visiting “Do Not Sell My Personal Information”.
Emailing us at [email protected]
Calling us toll free at 1-844-935-1470
Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request If you request access to or deletion of your personal information, we may require you to provide any of the following information: NPI Number (National Prescriber Identifier), First Name, Middle Name, Last Name, Office Street Address, City, State, Zip Code, Primary Phone Number, and Primary and Secondary Email Address. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).
Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
These Websites Are Not Intended for Children.
Data Security, Retention, and Integrity
The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect our stored data and information from unauthorized access, disclosure, use, and modification.
We regularly review our security procedures. Please be aware that, despite our best efforts, no security measures are perfect. If unauthorized access is detected and confirmed, we will communicate with you as appropriate.
We May Link to Other Sites or Have Third Party Services On Our Sites We Don't Control
If you click on a third party link, you will be taken to a website or platform we do not control. This policy does not apply to the privacy practices of that website or platform. Read other companies’ privacy policies carefully. We are not responsible for these third parties.
Changes to This Policy
From time to time, we may change this policy. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address we have on file, by posting notice of such changes on our websites, or by other means, consistent with applicable law.