The Privacy of your personal information is important to Physicians Postgraduate Press, Inc. (“PPP”). To better protect your privacy, we provide you with our Internet Privacy Policy so that you will understand both our commitment to you and to your privacy. This Privacy Policy describes what information we may collect about you; how we use your information; how we protect it; and what choices you have on how that information is used. At PPP, we understand that you may provide us with information about you that you may consider to be sensitive, and we want you to feel as comfortable as possible visiting our various web sites and using their respective services.

We will post privacy policy changes on our Web sites in a timely manner.

The following articles make up our Privacy Policy. We hope that reading them gives you a clear idea of how we manage information regarding you. For immediate access to a particular topic, click on the title of that topic.

I. Personal Information We Collect
II. Use of Your Information
III. Protection of Information; How PPP Handles Privacy Internally
IV. Your Privacy Choices
V. Updating Your Personal Information and Contacting PPP
VI. Children’s Privacy
VII. Additional Privacy Information for Users in the EU
VIII. Additional Privacy Information For California Users
IX. DMD Healthcare Communications Network Participation Disclosure

When we refer to ourselves as “we” or “PPP”, we mean our entire company, including any company that we control (for example, a subsidiary that we own) or an affiliated or related entity. We may share information among our subsidiaries that we own or control, or an affiliated or related entity, but it is always protected under the terms of this Privacy Policy.

This Privacy Policy applies to all PPP Web sites and only to such sites. You should read the Privacy Policy at each Web site that you visit after you leave one of our sites. We are not responsible for how other Web sites treat your privacy, once you leave a PPP site.

* To review definitions of key words, see our Glossary

I. Personal Information We Collect

In this section of our Privacy Policy, we discuss the different types of information we may collect about you, and the ways in which we collect information.

Information We Collect From Visitors

Visitors to each of our Web sites can access the Web site’s home page, and browse some areas of the site, without disclosing any personally identifiable information. We do track information provided to us by your browser, including the Web site you came from (known as the “referring URL”), the type of browser you use, the time and date of access, and other information that does not personally identify you. On some of our sites, you must register with us to use portions of the site.

Information We Collect When You Register

Visitors registering for services on our Web sites are asked to provide us with personal identifying information. Personal identifying information we collect may include, but is not limited to, identifiers such as your name, username and password, address (postal and email), telephone number, professional background and educational information, certain legally protected demographic information, such as your age, and inferences that can be drawn from that information. On our registration screen, we clearly label which information is required for registration, and which information is optional and may be given at your discretion. You will also be given a choice about whether or not you want to receive e-mail information.

Additionally, when visitors participate in Internet CME activities:

• We ask participants to complete an assessment of how well they achieved the objectives in order to provide feedback concerning the value of the activity. In addition, we may ask participants to complete a knowledge test as part of a CME activity in order to provide feedback concerning their understanding of the content.
• We ask participants to evaluate CME activities in order to improve those activities and future ones.
• We ask whether participants want to be notified of new CME activities as they become available on our site. If they want to change their status regarding this notification at a later time, they can change it themselves on the registration page or ask us to change it. (contact us.)

Your Choice

By using this site, you agree with the terms of this Privacy Policy. Whenever you submit information to this site, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy.

Information From Outside Sources

We may also collect information about physicians or other healthcare professionals who register on our Web sites from other sources in order to verify their licensure status and identity. In some cases, we ask customers for information after they register, such as credit card information. Where necessary (for example, to process an order for a purchase), our Web sites may contact financial or credit organizations to confirm customer credit card information and/or to complete the transaction.

National Provider Identifier (NPI) — We may collect NPI numbers from third parties and match those numbers to personal information in our system to provide you with content and advertisements tailored to your individual interests and needs.

 Third Party Social Media — If you choose to register and sign in using a third party social media account, the authentication of your login is handled by the third-party account and the Services may collect your name, profile photograph, email address, and any other information from your third-party account that you agree to share at the time you give permission to link your third-party account with the Services. By doing this, you are authorizing us to collect, store, and use the data they send us.

Other Information

• We also collect information that you voluntarily provide to us through responses to surveys, polling, questionnaires, and the like.
• When you are using a forum or message board on our Web sites, you are posting a message with your user name available for all registered users to see. When you are posting publicly, any user of our Web site can see your message. You should not post any information you want to keep private to a forum board or any other public forum on our Web sites.
• We may also ask you to provide additional information such as your email address if you want to obtain additional services or information or to resolve complaints or concerns.

In addition, we gather information about you that is automatically collected by our Web server, such as your IP address and domain name. PPP will use this information to personalize its offerings and presentations to you, facilitate your movements throughout our Web sites, provide personalized services, and communicate with you individually.

• Device Information — such as your hardware model, IP address, other unique identifiers, operating system version, browser type and settings, and the settings of the device you use to access a Service.
• Usage Information — such as information about the Services you use, the date and time, the duration of your usage, the files downloaded or viewed, and other information about your interaction with content offered through a Service.
• Geo-Location Information — such as the general location of your device in order to provide you with more relevant content and ads for where you are in the world when you use certain Services.

Use of Cookies and Other Tracking Systems

Cookies are a technology used by the PPP Web sites to identify a user as the user moves through our Web sites. Your browser allows us to place some information on your computer’s hard drive that identifies the computer you are using. We use cookies to personalize our Web sites and to track your usage across all of our Web sites.

Your Web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. If your browser is set to reject cookies, Web sites that are cookie enabled will not recognize you when you return to the Web site, and some Web site functionality may be lost; for example, our Web sites may not be able to authenticate you, and you may not be able to access parts of the Web sites.

On occasion, we contract with third parties to place Cookies on your computer’s hard drive. We have required these third parties to observe our Privacy Policy.

Notwithstanding any other provision in this privacy policy, for Advertisement Servers Tracking, some of the advertisements included on the Services are delivered or served by third parties that may collect anonymous information. These third parties may place or recognize cookies, pixel tags, web beacons or other technology to track anonymous information, in part, to measure and analyze the efficacy of the advertising they place at the Services. These third parties also may have the ability to link the information they collect when you use the Services, such as the identifier for the device you are using, with other information they collect elsewhere on the Internet to gain additional insights into their target audience.​

The Help section of your browser will tell you how to prevent your browser from accepting cookies.

Cookies do not normally contain personally identifiable information. If you have provided us information about yourself, we may associate your registration information with cookies our Web site places on your computer’s hard drive. Associating a cookie with your registration data allows us to offer increased personalization and functionality. For example, you will be able to use all of our sites after you have signed in to one of our sites. Without cookies, this functionality is not possible.

In some cases, we also work with third-party vendors to help deliver advertisements on our behalf across the Internet. These vendors may use cookies to collect information about your use of the Services (i.e., the pages you have visited) in order to help deliver particular ads that they believe you would find most relevant. You can opt out of third-party vendor use of cookies to tailor advertising to you by visiting http://www.networkadvertising.org/managing/opt_out.asp. If you choose to opt out, doing so may interfere with or prevent the proper function of a Service.

If you become aware that a PPP business partner is placing an unwanted cookie on your hard drive, please contact the privacy officer at PPP [email protected] to assist us in resolving the problem.

In addition, we may use other tracking systems. See Web Bugs and Log Files.

II. Uses We Make of Information

In this section of our Privacy Policy, we identify the ways we may use information about you that we have collected.

Information that you provide to us is used for several business purposes, including to process, fulfill, and deliver your requests for content and services and, where applicable, report points and credits to credentialing organizations. This includes, for example, processing your subscription, sending you content and updates (including by email) and enabling you to participate in the features provided by the Services. Through such features, we are able to bring you information and content tailored to your individual interests and needs. We also may contact you periodically with information, surveys, and offers relating to the Services, unless you have indicated you do not wish to receive such further information. You may unsubscribe from our email services at any time. For additional information on how to unsubscribe from our email services, please refer to the How to Make Changes to Your Information section of this Privacy Policy.

Information collected automatically is used to monitor users’ interests and usage patterns in order to help us enhance and improve our service offerings.

 We may share information with certain third parties, including vendors providing contracted services to us, such as hosting vendors, advertising service providers, data analytics and customer support providers, IT service providers, and list managers. We may also share your information, including your payment information, as appropriate to process your payment for a Service or to complete a transaction. When requested by you, we may also share your information with medical credentialing and accreditation organizations in connection with our continuing medical education and maintenance of certification offerings. These providers and organizations are obligated to maintain your personal information as confidential and have access to your personal information only as necessary to perform their requested function on your behalf.

Aggregate Data

We create aggregate data about visitors to our Web sites for the development and improvement of activities. We also use it for market analysis. We may provide information from our Web sites in aggregate form, with identifying information removed, to third parties. For example, we may tell a third party what percentage of our registered users reside in a particular geographical area. When aggregate protected information is provided, we pool it from many individual records and strip it of any data that could be used to identify an individual before it is used. Any third party that receives aggregated protected data must agree not to attempt to re-identify the people it belongs to. Depending on our agreement with the third parties, we may or may not charge for this information.

Marketing

We may target our marketing depending on information we have about you. For example, a user who we know has attended a CME activity may receive information related to the topic of the CME activity, or a user who we know is a healthcare professional who treats depression may receive information for new depression therapies.

We may also personalize our Web site based on your interests. For example, you may see different articles in different places on our Web site based on information you have shared with us, or information we have gained by reviewing your previous visits, or information we may have gained from your interactions with a third party that shares information with us.

When we share information with third parties, we ask that they agree in writing to abide by PPP privacy policies.

If we discover that a third party inappropriately disclosed personal information about any of our visitors, we will take immediate action to prevent further occurrences.

Institutional Member Network Privacy Policy

If you identify yourself as an affiliate of one of our Institutional Members (groups for whom we are providing records of CME participation), a report of your participation in CME activities offered on a PPP Web site will be forwarded to the institution you named in your user profile. This information will include your name and earned CME credits.

CME Activities

We use the information that we collect through CME/CE activities in several ways:

• We are accredited by the Accreditation Council for Continuing Medical Education (“ACCME”) to provide continuing medical education for physicians. As an ACCME accredited entity, we are required periodically to submit aggregated data about CME participants and the CME activities we certify. We also provide personally identifiable information to other accredited CME/CE providers who certify CME/CE activities posted on our Web sites, as required by the ACCME and other accrediting bodies. These reports may include personally identifiable information about you and credits issued to you, for the purpose of maintaining records that you can request from the accredited provider for up to six (6) years;
• Commercial supporters of CME/CE activities on our Web site will receive only aggregated data about CME/CE activities that are relevant to their interests and/or the courses they support;
• Our CME staff and customer support staff will have internal access to files containing personally identifiable information, including evaluation forms and aggregated CME /CE participant information. These files can be accessed in order to respond to your questions or comments. Our staff may also use personally identifiable information, including registration information and evaluation data, in assessing educational needs and planning marketing activities.

We may use the information we collect as otherwise permitted in this Privacy Policy.

Advertisers and Use of Personal Information

From time to time, we rent our print subscriber list, which includes personal identifiers such as subscriber names and postal addresses, to third parties that have products or services that we believe will be of interest to our customers. Even if we share our mailing lists with these other companies, however, please be assured we do not share your email address or credit card information. We may also share your name and email address with LinkedIn and other social media sites to provide you with tailored ads about our services. If you do not want us to rent your postal address information or share your name and email address with LinkedIn and other social media sites to provide you with tailored ads, contact us at [email protected].

Third party advertisements may link to websites not under our control. These third-party advertisers may use cookie technology or similar means to measure the effectiveness of their ads or may otherwise collect personally identifying information from you when you leave the Services. We are not responsible or liable for any content, advertising, products or other materials offered from such advertisers and their agents.

Transactions that occur between you and the third-party advertisers are strictly between you and the third-party and are not our responsibility. You should review the privacy policy of any third-party advertiser and its agent, as their policies may differ from ours.

Advertisement Servers and Third-Party Tracking

Some of the advertisements included on the Services are delivered or served by third parties that may collect anonymous information.  These third parties may place or recognize cookies, pixel tags, web beacons or other technology to track anonymous information, in part, to measure and analyze the efficacy of the advertising they place at the Services.  These third parties also may have the ability to link the information they collect when you use the Services, such as the identifier for the device you are using, with other information they collect elsewhere on the Internet to gain additional insights into their target audience.

III. Protection of Information

How PPP Handles Privacy Internally

In this section of our Privacy Policy, we discuss the security measures we take to protect information that we have collected about you.

Our Commitment to Security

We have put in place physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and ensure correct use of information we collect online.

General Policies

We have implemented technology and security policies, rules, and other measures to protect the personal data that we have under our control from unauthorized access, improper use, alteration, unlawful or accidental destruction, and accidental loss. We also protect your information by requiring that all our employees and others who have access to, or are associated with, the processing of your data respect your confidentiality.

PPP uses security methods to determine the identity of its registered users so that appropriate rights and restrictions can be enforced for that user. Reliable verification of user identity is called authentication. PPP uses both passwords and usernames to authenticate users. In certain restricted and limited situations IP addresses are used for authentication instead of the password and user name. Users are responsible for maintaining their own passwords.

We regularly test and update our technology to help protect your personal information. However, such precautions do not guarantee that our Web site is invulnerable to all security breaches. We make no warranty, guarantee, or representation that use of our Web site is protected from all viruses, security threats or other vulnerabilities and that your information will always be secure.

Third Parties

In addition to aggregate information (discussed previously), we may share some kinds of information with third parties as described below.

• Companies and People Who Work for Us: We contract with other companies and individuals to help us provide services. For example, we may host some of our Web sites on another company’s computers, hire technical consultants to maintain our Web-based health sites, or work with companies to remove repetitive information from customer lists, analyze data, provide marketing assistance, and provide customer service. In addition, if you are a healthcare professional, we may validate your licensure status and other information against available databases that list licensed health care professionals. In order to perform their jobs, these other companies may have limited access to some of the personal information we maintain about our users. We require all such companies to comply with the terms of our privacy policies, to limit their access to any personal information to the minimum necessary to perform their obligations, and not to use the information they may access for purposes other than fulfilling their responsibilities to us. We use our best efforts to limit the use of other companies in areas where personally identifiable information may be involved.
• Promotional Offers: Sometimes we send offers to selected groups of visitors. We provide a variety of mechanisms for you to tell us you do not want to receive such promotional offers. For example, we may provide an opt-in box for customers to receive a coupon or information that is sent by a third party fulfillment house, and we make clear that, by opting in, you are submitting your data to a third party. You can elect not to receive promotional material from us by sending us an e-mail to [email protected] .
• Legal Requirements: We may release account and other personal information when we believe release is required to comply with law. We may release protected information, if, in our judgment after review by an attorney, the release is compelled by law or regulation, or if the release may be necessary to prevent the death or serious injury of an individual.

IV. Your Privacy Choices

On certain of our sites, when you complete Registration of your Profile, you will be given the option of receiving recurring informational/promotional e-mails from PPP and/or third parties. You may opt-out from receiving these e-mails when you provide the information at any time. We may also ask for contact information (such as, name and email address) if you wish to request e-mail information. You can unsubscribe from such e-mails very easily. When you have received an e-mail message from a program you wish to stop follow the unsubscribe instructions on such e-mail, if any, or click on the “Forward” button in your mail program, then send us an e-mail with the subject unsubscribe to [email protected] . PPP will then unsubscribe you from receiving such e-mails.

Choice

You will be given the opportunity to choose (opt-out) whether your personal information is (a) to be disclosed to a third party or (b) to be used for a purpose that is different from the purpose originally intended or authorized by sending an e-mail to [email protected] . In addition for certain protected sensitive information you will be given an affirmative or explicit opt-in choice.

V. Updating Your Personal Information and Contacting PPP

We have provided you access to your personal information so that you may: (a) delete the Personal Information that you have provided to us from our systems, and (b) update the Personal Information that you have provided to us.

You can also contact us in order to change your preferences that you have provided us by e-mailing us at [email protected].

VI. Children’s Policy

We are committed to protecting the privacy of children. You should be aware that this Site is not intended or designed to attract children under the age of 13. We do not collect personally identifiable information from any person we actually know is a child under the age of 13.

VII. Additional Privacy Information for Users Outside of the United States

PPP and our technical infrastructure are located in the United States.  The personal information that you provide to us is stored on servers located in the United States. If you are located in another jurisdiction, you should be aware that in order to provide the Services to you, we must transfer your personal information to the United States where it will be stored and processed in accordance with this Privacy Policy. We may transfer your information outside the United States to service providers with operations in other countries. By using the Services, you consent to such collection, storage and processing in the United States and elsewhere, though the United States and other jurisdictions may not afford the same level of data protection as considered adequate in your own country. We will take reasonable steps to protect your personal information. Note that your personal information may be available to the United States government or its agencies under legal process made in the United States.

Additional Information for PPP’s Visitors from the European Economic Area (“EEA”)

When you use the Services, we collect, store, use and otherwise process your personal information as described in this Privacy Policy. We rely on a number of legal bases to process your information, including where: (i) necessary for our legitimate interests in providing and improving the Services including offering you content and advertising that may be of interest to you; (ii) necessary for our legitimate interest in keeping the Services, Sites and Apps safe and secure; (iii) necessary for the legitimate interests of our service providers and partners; (iv) necessary to perform our contractual obligations in the PPP Terms of Use; (v) you have consented to the processing, which you can revoke at any time (however a revocation does not affect the lawfulness of processing of your personal data that occurred prior to the date of revocation); (vi) you have expressly made the information public, e.g., in public forums; (vii) necessary to comply with a legal obligation such as a law, regulation, search warrant, subpoena or court order or to exercise or defend legal claims; and (viii) necessary to protect your vital interests, or those of others.

If you are a PPP user in the EEA, you can: (i) access personal information we have about you (we will try to provide information within 30 days of your request); (ii) have your personal information corrected or deleted (in most cases you can correct personal information you have submitted to us by going back to the specific Service, logging-in and making the desired change); (iii) in certain circumstances, you can object to our processing of your personal information and we will discontinue such processing unless we have compelling legitimate grounds to continue; (iv) withdraw consent previously provided (however a withdrawal does not affect the lawfulness of processing of your personal data that occurred prior to the date of withdrawal); or (v) if you believe that we have not complied with applicable data protection laws, you may lodge a complaint with your local supervisory authority. If you wish to inquire as to whether we maintain any of your personal information and if so, whether you wish to exercise any of those rights that are available to you with respect to such personal information, you may contact us as described in the Contacting PPP About Your Personal Information or Privacy section below. We will respond to your request within a reasonable timeframe.

Where we process your personal information for direct marketing purposes, you can opt-out through the unsubscribe link in the email communications we send to you, by changing your subscription preferences in your account settings or as otherwise specified in this Privacy Policy.

We will retain your personal information for as long as necessary to provide the Services to you and fulfill the purposes described in this Privacy Policy. This is also the case for third parties within whom we share your information to perform services on our behalf.  When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it.  If you have registered with PPP and you no longer want us to use your registration information to provide the Services to you, you may close your account.

Contacting PPP About Your Personal Information or Privacy

Please send us an email by using the Contact Us link at the bottom of every page of the PPP Sites if you have any questions about this Privacy Policy or the personal information we maintain about you. We will respond to your request within a reasonable timeframe.

You can also contact PPP’s Privacy Office at:

Physicians Postgraduate Press, Inc.
Attn: Privacy Officer
850 Ridge Lake Blvd
Suite 300
Phone: (800) 489–1001 or (901) 751–3800

VIII. Additional Privacy Information For California Users

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of PPP and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to our users who are residents of the State of California (“consumers” or “you”) in relation to your use of our owned and operated websites that are intended for use by Healthcare Professionals, and may also be used by consumers (non-professionals) for non-commercial personal, family or household purposes and including the mobile optimized versions of these sites and our Mobile Device Applications or “Apps” (we refer to these sites and Apps collectively as the “PPP Sites”). We refer to the PPP Sites and Apps, along with the information and services made available to you through the PPP Sites and Apps, as the “Services”.

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in our Privacy Policy or in the CCPA have the same meaning when used in this notice.

Information we collect.

We have collected the following categories of information from consumers within the last twelve (12) months:

Category	Examples	Collected
A.  Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
B. Personal information listed under Cal. Civ. Code § 1798.80(e).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes
C.  Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes
D.  Commercial Information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E.  Biometric Information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Yes
F.  Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
G.  Geolocation data.	Physical location or movements.	Yes
H.  Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I.  Professional or employment-related information.	Current or past job history or performance evaluations.	No
J.  Non-public education information.	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K.  Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes

Certain information that we collect identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular professional user, consumer, or household (“personal information”).

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
  • Information included in categories D, E, F, G and K is collected and used in a de-identified and/or aggregated manner.
• Information excluded from the CCPA’s scope, such as:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Categories of sources from which information is collected.

As described in our Privacy Policy, we may obtain the categories of personal information listed above from the following categories of sources:

• Directly from you, such as when you register with PPP.
• Indirectly from you, such as information we may collect in the course of providing the Services.
• Directly and indirectly from your activity on our Sites and Apps, as described below under Services and device information and Cookies and other tracking technologies.
• From third parties that interact with us in connection with the Services, such as from healthcare professional or consumer data providers for research and analytics purposes as described below under

Use of your personal information.

Services and Device Information

When you access and use the Services, PPP automatically collects and stores in its server logs information from your browser or mobile device such as your IP address or unique device identifier, browser information (including referring URL), your preferences and settings, cookies and information about the content you have viewed and actions taken (e.g., search queries, ad engagement, clicks and the associated dates and times). PPP may also collect device-specific information when you install and use an App including your device model, operating system information, advertising ID (which is a unique, user-resettable identification number for advertising associated with a mobile device) and App version and usage information. When enabled by you, we collect precise location information provided by your mobile device, which you may disable through the device settings.

Cookies and Other Tracking Technologies

We and our partners use cookies to collect information about your use of the Services. “Cookies” are small data files assigned to your browser when you visit a PPP Site which enable recognition of your browser and collect and store information about your use of the Services, as described above. In addition to cookies, we and our partners use other tracking technologies that collect information about your use of the Services, including mobile identifiers and “web beacons” which are small graphic files (sometimes called “clear GIFs” or “web pixels”) embedded in a web page or email typically used to monitor activity and send relevant information back to a home server (which can belong to the host site, a network advertiser or some other third party). The information collected by such tracking technologies may be combined with other information that our partners have access to, including your name, email address and physical address, so that we can send you materials, either electronically or by direct mail, that may be of interest to you.

Our advertising service partners may use cookies and other tracking technologies to collect information about your use of the PPP Sites, including content you have viewed. These third parties may use this information to help PPP deliver advertising on the PPP Sites and on other third party websites based on your browsing activity on the PPP Sites. PPP may further tailor the advertising on the PPP Sites and these other third party websites based on additional information to the extent known by PPP or these third parties. Two of the third parties that PPP works with are Google and Facebook. In addition to using the information it collects performing services for PPP, Google may also use such information as described in its privacy policy. To see how Google may use information collected through our use of the Google services on the PPP Sites visit https://www.google.com/policies/privacy/partners. While Facebook does not provide any personal information to PPP, Facebook may use information that it has about you and that it collects performing services for PPP (which may be associated with personal information that Facebook has about you) as described in its privacy policy available at https://www.facebook.com/about/privacy.

We also work with third party ad networks to display advertising on our PPP Sites and on third party websites. Our ad network vendors use technologies to collect information about your activities on the PPP Sites and in our flagship PPP App to provide you cookie-based targeted advertising on our PPP Sites and on third party websites based upon your browsing activity and your interests.

For more information about our how cookies and other tracking technologies are used in connection with the Services, please read our “Use of Cookies and Other Tracking Systems” policy.

When you download and install one of our Apps onto your mobile device we assign a random number to your App installation. This number cannot be used to identify you personally, and we cannot identify you personally unless you choose to become a registered user of the App. We use this random number in a manner similar to our use of cookies as described in this Privacy Policy and in our “Use of Cookies and Other Tracking Systems” policy. Unlike cookies, the random number is assigned to your installation of the App itself and not a browser, because the App does not work through your browser. Therefore the random number cannot be removed through settings. If you do not want us to use the random number for the purposes for which we use cookies, please do not use the Apps. Our use of cookies and other tracking technologies on our mobile optimized sites and our flagship PPP App are similar to our use on our desktop sites. Your choices to reject cookies, use the Network Advertising Initiative and the opt-out mechanism described below in the section “Your Choice“ are available on our flagship PPP App and on our mobile optimized sites.

Use of personal information.

Your personal information included in each of categories A, B and C described above may be used for the following business purposes:

• to provide, improve and create new Services,
• to respond to your inquiries and to send you administrative communications about the PPP Sites and Services,
• to obtain your feedback about the PPP Sites and Services,
• to send you secure electronic messages and personalized emails pertaining to your interests as inferred from your use of the Services, including news, announcements, reminders and opportunities from PPP,
• to statistically analyze trends and user behavior and activity including how frequently areas of the PPP Sites are visited, how the Services are being used and how many emails are received and opened,
• to provide you and people with similar demographic characteristics and interests with more relevant content including advertising both on and off the PPP Sites and Apps,
• to offer lead generation services,
• to detect and defend against fraud and other threats to the Services and our users,
• to identify issues with the Services,
• to conduct research and measurement activities, including those described below, and
• to administer your account.

In addition, PPP may use personal information about you for other purposes that are disclosed to you at the time we collect the information and/or with your consent.

PPP may combine your personal information and other information collected about your use of the Services, and also supplement with information from external sources for the purposes described in this privacy notice. For example, information that PPP collects about you may be combined by PPP with other information available to PPP through third parties for research and measurement purposes, including measuring the effectiveness of content, advertising or programs. This information from other sources may include age, gender, demographic, geographic, personal interests, product purchase activity or other information. We may report aggregate information, which is not able to be identified back to an individual user of the PPP Sites, to our current or prospective advertisers and other business partners.

Sharing your personal information

Personal information disclosed for a business purpose

We may share your information with our subsidiaries, affiliates and companies acquired by or merged with us and our affiliates.

PPP works with third party companies that help us provide the Services and to otherwise assist in the operation of the PPP Sites and Apps, including those that provide services relating to technology, data analysis, research, email management and deployment, sweepstakes and contest administration, advertising and marketing and/or content. PPP service providers sometimes have limited access to your information in the course of providing products or services to PPP. We contractually require that our service providers not use or disclose your information for any purpose other than providing the limited service or function for PPP.

In the preceding twelve (12) months, we have disclosed your personal information included in each of categories A, B and C for a business purpose.

We disclose your personal information for a business purpose to the following categories of third parties: (i) service providers, and (ii) third parties to whom you or your agents authorize us to disclose your personal information in connection with the Services.

Personal information “sold” to third parties

We may share information that we have about you, such as a cookie ID or IP address, with third party advertising partners who may use this information, on our behalf, to help PPP deliver advertising on the PPP Sites as well as on third party websites.

In the preceding twelve (12) months, we have made available your personal information included in category A to third parties for advertising services.

For more information about our use of cookies and other tracking technologies, please read our Use of “Cookies and Other Tracking Systems” policy.

We do not sell the personal information of consumers that we know are minors under 16 years of age without affirmative authorization as required under the CCPA.

Your rights

The CCPA provides California consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to specific information and data portability rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• the categories of personal information we collected about you.
• the categories of sources for the personal information we collected about you.
• our business or commercial purpose for collecting or selling that personal information.
• the categories of third parties with whom we share that personal information.
• the specific pieces of personal information we collected about you (also called a data portability request).
• if we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

Deletion rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• debug products to identify and repair errors that impair existing intended functionality.
• exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• comply with a legal obligation.
• make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to opt out of the sale of your personal information

You have the right to opt out of the sale of your personal information subject to certain exclusions as described below. Once we receive your request, we will not sell your personal information, unless an exclusion applies. We may request that you authorize the sale of your personal information after 12 months following your opt-out.

The CCPA excludes certain transfers of your personal information from what constitutes a sale thereof:

• As directed by you:
  • When you direct us to intentionally disclose your personal information or use the Services to intentionally interact with us or a third party (provided that third party does not sell your personal information, unless that disclosure would be consistent with the CCPA).
• Opt-out signal:
  • We may share an identifier for you if you have opted out of the sale of your personal information for the purposes of alerting third parties of your election.
• Service provider:
  • We may share your personal information with a service provider that is necessary to perform a business purpose as described above if both of the following conditions are met:
    • we provide notice of the sharing and your opt-out right as described herein.
    • the service provider does not further collect, sell, or use the personal information of the consumer except as necessary to perform the business purpose.
• Change of control:
  • We may transfer to a third party your personal information as an asset that is part of a merger, acquisition, bankruptcy, or other transaction subject to certain requirements described in the CCPA.

We are unable to process opt-out requests across devices or the Apps for advertising services described herein. For example, if you opt out on your browser, we are not able to honor that request if you are using one of our Apps due to our practices and the limitations described above. Please see below on how to opt out across devices.

Exercising access, data portability and deletion rights

To exercise the access, data portability and deletion rights described above, please submit a request to us by either:

• Calling Privacy Officer at (800) 489–1001 or (901) 751–3800.
• Sending an email to [email protected].

By calling the toll-free number or using the above email, you will be asked to provide certain identifying information, such as name, email, residency and date of birth, which we will only use to process or verify your request. You will be asked to validate your request by clicking a validation link in an email that will be sent to the email address provided.

The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You may be asked to provide further verifying documentation, such as proof of residency and identity.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide proof of written authorization to do so, and you must verify your identity directly with us, unless such authorized agent provides proof of a power of attorney pursuant to Probate Code sections 4000 to 4465.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Exercising your opt-out right.

Notice of the Right to Opt-Out of the Sale of Personal Information for California Residents

We offer our users certain choices about how we use their information. The California Consumer Privacy Act (“CCPA”) provides to California residents the right to opt out of the “sale” of their personal information as more fully described in our Privacy Notice for California Residents.

Personalized Advertising

The CCPA defines “sale” broadly, and it may include our sharing information that we have about you, such as a cookie ID or IP address, with third party advertising partners who may use this information, on our behalf, to help us deliver advertising on the PPP Sites as well as on third party websites.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  Any disclosures we provide will cover a period of no less than 12 months preceding the receipt of a verifiable consumer request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We may provide a different level of Services if the difference is reasonably related to value provided by your data.

Changes to this privacy notice

We reserve the right to change or modify this privacy notice and any of our Services at any time and any changes will be effective upon being posted unless we advise otherwise. By continuing to use the Services after changes are made to this privacy notice, you agree to such changes.  We encourage you to periodically review this privacy notice for the latest information on our privacy practices.

Contact information

Please send us an email by using the Contact Us link at the bottom of every page of the PPP Sites if you have any questions about this privacy notice or the personal information we maintain about you. We will respond to your request within a reasonable timeframe.

You can also contact PPP’s Privacy Office at:
Physicians Postgraduate Press, Inc.
Attn: Privacy Officer
850 Ridge Lake Blvd
Suite 300
Phone: (800) 489–1001 or (901) 751–3800

Changes to this Privacy Policy

We reserve the right to change or modify this Privacy Policy and any of our Services at any time and any changes will be effective upon being posted unless we advise otherwise. If we make any material changes to this Privacy Policy we will notify you by means of a notice on the PPP Sites and/or by email to our registered users (sent to the email address specified when you register) prior to the change becoming effective. By continuing to use the Services after changes are made to this Privacy Policy, you agree to such changes.  We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. If you do not accept the terms of this Privacy Policy, we ask that you do not register with us and that you do not use the PPP Sites. Please exit the PPP Sites immediately if you do not agree to the terms of this Privacy Policy.

IX. DMD Healthcare Communications Network Participation Disclosure

This website is a member of the DMD Healthcare Communications Network (the “HCN”).  HCN is owned and managed by DMD Marketing Corp (“DMD”) and is designed to enable DMD and HCN members to provide medically relevant business communications to authenticated health care professionals.

Your registration at this website includes registration with HCN. As a result, your contact and other professionally relevant information will be disclosed to DMD and each HCN member to provide you medically relevant content as described the HCN privacy policy available at https://HCN.health/privacy-policy/. The HCN privacy policy provides details on how to manage your information, including opting out of participation in the HCN.

To the extent that this site’s privacy policy conflicts with the HCN privacy policy, with respect to the use of this information by HCN, the conflict will be resolved in favor of the HCN policy.

Last updated on September 14, 2021