At WebMD Ignite, we understand the importance of your privacy. This Privacy Notice (“Privacy Notice") explains our privacy practices for the activities we describe below. Please read this Privacy Notice carefully to learn how we collect, use, share, and otherwise process Personal Data that we collect or receive as described below and to learn about your rights and choices regarding Personal Data that we collect about you. “Personal Data” means information that identifies individual persons, or that we are reasonably able to link to or associate with identifiable individuals.
A reference to “WebMD Ignite,” “we,” or “us” is a reference to WebMD Ignite, Inc. and its relevant affiliate involved in the collection, use, sharing, or other processing of Personal Data.
Important Explanation about this Privacy Notice
We do not sell products or services directly to consumers, and this Privacy Notice does not apply to the extent we process Personal Data in the role of a processor or service provider on behalf of our business customers. This means that this Privacy Notice does not apply where we offer to our customers various cloud products and services through which our customers or their affiliates: (i) sell or offer their own products and services; (ii) send or use our platform to send electronic communications to others, or where we send electronic communications on our customers’ behalf; (iii) operate running on our platform; or (iv) otherwise collect, use, share or process Personal Data via our cloud products and services.
For privacy information related to a WebMD Ignite customer or a customer affiliate who uses the WebMD Ignite cloud products and services, please contact the customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Notice. For more information, please also see Section 9.4 below.
This Privacy Notice also does not apply to Personal Data concerning our employees or contractors.
1. Scope of this Privacy Notice
This Privacy Notice applies to the processing of Personal Data collected by us when you:
- Visit our websites or mobile apps (collectively, “Sites”) that display or link to this Privacy Notice;
- Receive communications from us, including emails, phone calls, or texts;
- Use our cloud products and services as an authorized user (for example, as an employee of one of our customers who provided you with access to our services) where we act as a controller of your Personal Data; or
- Register for, attend, or take part in our events, webinars, podcasts, or contests.
Our Sites and services may contain links to other Sites and services maintained by third parties. The information practices of other services are governed by their Privacy Notices, which you should review to better understand their privacy practices.
What Personal Data do we collect?
1. Personal Data we collect directly from you
The Personal Data we collect directly from you includes identifiers, professional or employment-related information, commercial information, and internet activity information. We collect this information in the following situations:
- If you express an interest in obtaining additional information about our services; request customer support; use our “Contact Us,” “Let’s Talk,” or similar features; register to use our Sites or cloud services; sign up for an event, webinar, podcast, or contest; or download certain content, we may require that you provide to us identifiers such as your name, job title, company name, address, phone number, email address, or username and password;
- If you interact with our Sites or emails, we automatically collect information about your device and your usage of our Sites or emails such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Data (please see the “What device and usage data do we process” section, below) using cookies, web beacons, or similar technologies;
- If you use and interact with our services, we automatically collect information about your device and your usage of our services through log files and other technologies, some of which may qualify as Personal Data (please see the “What device and usage data do we process” section, below);
- If you communicate with us via a phone call, we may record that call; and
- If you voluntarily submit certain information to our services, such as filling out a survey about your user experience, we collect the information you have provided as part of that request.
If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so, are doing so in compliance with applicable law, and where required, have obtained the necessary consent, and acknowledge that the Personal Data may be used in accordance with this Privacy Notice. If you believe that Personal Data about you has been provided to us improperly, please contact us by using the information in the “Contacting us” section below.
2.2 Personal Data we collect from other sources
We may collect information about you from consumer data companies and other sources and from publicly available information. We may combine this information with Personal Data provided by our customers. This helps us update, expand, and analyze our records and provide and enhance our products and services for customers, including creating more tailored advertising for our customers. The Personal Data we collect from other sources may include identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information and inferences about preferences and behaviors.
1.What device and usage data do we process?
We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons, pixels, and similar technologies to automatically collect information that may contain Personal Data as you navigate our Sites or services, or interact with emails we have sent to you.
3.1 Device and usage data
As is true of most Sites, we gather certain information automatically when individual users visit our Sites. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server information), device and application information, identification numbers and features, location, browser type, plug-ins, integrations, Internet service provider, mobile carrier, the pages and files viewed, searches, referring website, app or ad, operating system, system configuration information, advertising and language preferences, date and time stamps associated with your usage, and frequency of visits to the Sites. This information is used to analyze overall trends, help us provide and improve our Sites, offer a tailored experience for website users, and secure and maintain our Sites.
In addition, we gather certain information automatically as part of your use of our cloud products and services. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server), mobile device number, device and application identification numbers, location, browser type, Internet service provider or mobile carrier, the pages and files viewed, website and webpage interactions including searches and other actions you take, operating system and system configuration information and date and time stamps associated with your usage. This information is used to maintain the security of the services, to provide necessary functionality, to improve performance of the services, to assess and improve customer and user experience of the services, to review compliance with applicable usage terms, to identify future opportunities for development of the services, to assess capacity requirements, to identify customer opportunities, and for the security of WebMD Ignite generally in addition to the security of our products and services. Some of the device and usage data collected by the services, whether alone or in conjunction with other data, could be personally identifying to you.
3.2 Cookies, web beacons and other tracking technologies on our website and in email communications
When you visit our websites, we, or an authorized third party, may place a cookie on your device that collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track use, infer-browsing preferences, and improve and customize your browsing experience.
We also use web beacons and pixels on our websites and in emails. For example, we may place a pixel in marketing emails that notify us when you click on a link in the email. We use these technologies to analyze the use of our websites, interactions with our emails, and the success of our marketing and website design efforts; to operate and improve our websites and marketing emails; and for other purposes relating to our marketing operations and the marketing services that we provide to our customers. For instructions on how to unsubscribe from our marketing emails, please see Section 9.1 below.
The following describes how we use different categories of cookies and similar technologies and your options for managing the data collection settings of these technologies:
3.3 Notices on behavioral advertising and opt-out for website visitors
As described above, we or one of our authorized partners may place or read cookies on your device when you visit our websites for the purpose of serving you targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). To learn more about targeted advertising and advertising networks or to opt out of targeted advertising, please visit the opt-out pages of the Network Advertising Initiative, and the Digital Advertising Alliance.
To manage the use of targeting and advertising cookies on this website, click the Cookie and Privacy Preferences link in the footer of the page or consult your individual browser settings for cookies.
3.4 Opt-Out from the setting of cookies on your individual browser
In addition to using the Cookie and Privacy Preferences, in many cases you may opt-out from the collection of non-essential device and usage data on your web browser (see the “What device and usage data we do process” section, above) by managing your cookies at the browser or device level. Please note, however, that by blocking or deleting cookies and similar technologies used on our websites, you may not be able to take full advantage of the websites.
While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard adopted by industry groups, technology companies, or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals with respect to our websites.
3.5 Social Media Features
Our Sites may use social media features, such as the Facebook “like” button, the “Tweet” button and other sharing widgets (“Social Media Features”). Social Media Features may allow you to post information about your activities on our website to outside platforms and social networks. Social Media Features may also allow you to like or highlight information we have posted on our website. Social Media Features are either hosted by each respective platform or hosted directly on our website. To the extent the Social Media Features are hosted by the platforms themselves, and you click through to these from our Sites, the platform may receive information showing that you have visited our Sites. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our Sites with your social media profile.
Your interactions with Social Media Features are governed by the privacy policies of the companies providing them.
1.Purposes for which we process Personal Data
We collect and process Personal Data about you for the following purposes:
- Providing our Sites and services, including functionality for both.
- Promoting the security of our Sites and services, including tracking use of our Sites and services, creating aggregated non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies to the extent we deem necessary to promote the safety and security of our Sites, services, and IT systems or protect our rights and the rights of others.
- If you fill out a “Contact Me” or “Let’s Talk” web form or request user support, or if you contact us by other means including via a phone call, we process Personal Data to fulfill your requests and otherwise to communicate with you for marketing or other purposes.
- We process Personal Data to plan and host events, podcasts, or webinars for which you have registered or that you attend, including sending related communications to you, and to otherwise communicate with you for marketing or other purposes.
- We process Personal Data to analyze trends and to track your usage of and interactions with our Sites and services to develop and improve our Sites and services and provide our users with more relevant content and service offerings.
- We process device and usage data as described in Section 3.1 above, which in some cases may be associated with Personal Data, to analyze trends, assess and improve the overall user experience, and develop and improve our service offerings.
- We process Personal Data to review compliance with our User Agreement or the applicable usage terms in our customer’s contract.
- We process Personal Data to assess new potential customer opportunities.
- We may record phone calls for training, quality assurance, and administration purposes.
- We process Personal Data to conduct marketing research, advertise to you, provide personalized information about us on and off our Sites and to provide other personalized content based upon your activities and interests.
- We will process Personal Data to communicate with you about products or services you may find of value, and otherwise to send marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events.
- We process Personal Data as required by applicable law, to protect against fraud or illegal activity, in cooperation with public and government authorities, courts or regulators, to protect our rights, to protect against misuse or abuse of our Sites or services, to protect personal property or safety, to exercise or defend legal claims, to pursue remedies available to us and limit our damages, to comply with judicial proceedings, court orders or legal processes, to respond to lawful requests, or for auditing purposes.
We may process Personal Data for other purposes that are compatible with the purposes above, or for which we receive your consent.
1.Who do we share Personal Data with?
We may share your Personal Data with the following categories of recipients:
- Service providers who provide services such as IT and system administration and hosting, research and analytics, marketing, customer support, data enrichment services, or other services.
- If you use our services as an authorized user, we may share your Personal Data with our applicable customer responsible for your access to the services, such as to verify accounts and activity, investigate suspicious activity, or enforce our terms and policies.
- With third-party advertising networks, social media networks, and websites and mobile apps, so WebMD Ignite can market and advertise on third party platforms, websites, and apps.
- We may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers - including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
- With affiliates within the WebMD Ignite corporate group and companies that we acquire in the future after they are made part of the WebMD Ignite corporate group.
We may also share Personal Data about you if we are involved in a merger, reorganization, dissolution, or other fundamental corporate change or sell a website, product, or business unit, or if all or a portion of our business, assets, or stock are acquired by a third party.
WebMD Ignite reserves the right to share or transfer Personal Data as we determine in our sole discretion to be necessary or appropriate in the following circumstances: to comply with a legal requirement; to enforce our terms and conditions; to protect our operations or those of any affiliate of WebMD Ignite; to protect our rights, privacy, safety, or property, or that of any affiliate of WebMD Ignite, you, or others; to disclose any activities or information about you to law enforcement or other government officials, including public or government authorities outside your country of residence; in connection with an investigation of fraud, intellectual property infringements, or activity that is illegal or may expose us or you to legal liability; in cooperation with various law enforcement inquiries; to allow us to pursue available remedies or limit our damages; or in emergency situations.
We may also share anonymous or de-identified data with third parties. For example, we may share such information publicly to show trends about the general use of our services.
1.International transfer of Personal Data
WebMD Ignite is based in the United States of America and offers our products and services to customers operating in the United States. Our information technology systems and networks that provide our Sites and services are located in the United States and potentially in other jurisdictions. Personal Data that persons outside the United States submit to our Sites or services may be transferred to or processed in the United States or other jurisdictions that may not provide for the same level of data protection as your jurisdiction of residence.
Our Sites are not directed at children. We do not knowingly collect Personal Data from children under the age of 18. If you are a parent or guardian and believe your child has provided us with Personal Data, please contact us by using the information in the “Contacting us” section below.
1.How long do we keep your Personal Data?
We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the “Purposes for which we process Personal Data” section, above), as long as required to fulfill our legal obligations, or otherwise in accordance with our record retention procedures.
1.Your choices and rights concerning Personal Data
9.1 Your preferences for email and SMS marketing communications
If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from WebMD Ignite by clicking on the “unsubscribe” link located on the bottom of WebMD Ignite marketing emails.
Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your or our relevant customer’s current relationship with us, such as communications about your or our customer’s subscriptions or event registrations, service announcements, or security information. Please also see “Your rights relating to customer data” below.
9.2 Direct Marketing
You may opt-out from all future use and disclosure of Personal Data about you for direct marketing purposes by WebMD Ignite by requesting the removal of Personal Data about you from our database as described in the "Your rights relating to Personal Data" section below.
9.3 Your rights relating to Personal Data
At any time, you may contact WebMD Ignite to request:
- A summary of any Personal Data that WebMD Ignite maintains about you;
- A change to the Personal Data that WebMD Ignite maintains about you; or
- Removal of the Personal Data WebMD Ignite maintains about you from its database.
You should send your request to ConsumerPrivacy@mercuryhealthcare.com. In the event WebMD Ignite receives such a request, WebMD Ignite may require you to confirm or verify any change to the applicable Personal Data. Except as otherwise required by applicable law, we will fulfill your request if reasonably possible, and subject to “Your rights relating to customer data” below.
9.4 Your rights relating to customer data
As described above, we may also process Personal Data submitted by or for a customer to our cloud products and services. We process such Personal Data as a processor on behalf of our customer (and its affiliates) who is the controller of the Personal Data. We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those explained in this Privacy Notice. If your data has been submitted to us by or on behalf of a WebMD Ignite customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly. If you wish to make your request directly to us, please provide us the name of the WebMD Ignite customer who submitted your data to us. We will refer your request to that customer.
1.How we secure your Personal Data
We take precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, or alteration, and unauthorized disclosure of or access to, the Personal Data we process or use.
While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your passwords, limiting access to your devices, and signing out of Sites after your sessions.
1.Changes to this Privacy Notice
We may update this Privacy Notice from time-to-time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “effective date” at the top. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you directly, or where required under applicable law and feasible, we may seek your consent to these changes.
We encourage you to periodically review this Privacy Notice to stay informed about our collection, processing, and sharing of Personal Data.
If you have questions regarding this Privacy Notice or our privacy practices, please send any questions or comments to WebMD Ignite to the e-mail address ConsumerPrivacy@mercuryhealthcare.com.
1.Additional Disclosures for California Consumers
If you are a California resident, the following provisions apply to our processing of information that identifies, relates to, describes, or is reasonably capable of being associated with you, or could reasonably be linked, directly or indirectly, with you (“California Personal Information”). For such residents, the provisions of these Additional Disclosures for California Consumers supplement and prevail over any conflicting provisions in our Privacy Notice.
13.1 California Personal Information We Collect
We have collected the following categories of California Personal Information within the last 12 months:
Category Examples Identifiers. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers. Information under the California Customer Records statute. Personal information described in subdivision (e) of Section 1798.80 (California Customer Records statute). This means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, name, address, telephone number, education, employment, or employment history, and household data. Commercial information. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Internet or other similar network activity. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, information regarding a consumer’s interaction with an internet website, application, or advertisement, browser type, domain names, access times, and referring website addresses. Geolocation data. Geolocation data. Professional or employment-related information. Current or past job history, job title, and education level. Inferences drawn from other personal information. Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, healthcare trends or propensities, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
For each of these categories, we obtain California Personal Information from a variety of sources. These sources include: yourself; other entities with whom you transact; others with whom you maintain relationships who may deal with us on your behalf; the devices you use to access our websites, mobile applications, and online services; credit bureaus; public databases; social media platforms; companies that supply consumer data to WebMD Ignite; our customers; and others consistent with this Privacy Notice. Please see the “What Personal Data do we collect?” section of our Privacy Notice.
13.2 Sale and Disclosure of California Personal Information
We have disclosed the following categories of Personal Information to other businesses or third parties for monetary or other valuable consideration within the twelve (12) months preceding the effective date of this Privacy Notice:
Identifiers, Characteristics of Protected Classifications, and Inferences. Names, addresses, email addresses, telephone numbers, demographic data such as age and gender, and psychographic profile information such as interest in sports or technology.
Identifiers and Inferences. Pseudonymous identifiers for individuals who visit our websites and mobile apps and the devices such individuals use to visit our websites and mobile apps, data relating to usage of our websites and apps and inferences drawn from such usage data, and data acquired from third party marketing and digital advertising providers. We share this information with third party vendors that provide consumer behavioral analytics, social media, and digital advertising services to WebMD Ignite, and where applicable these vendors may use the information for their own purposes.
Within the last 12 months, we have disclosed California Personal Information identified in the above categories for our business purposes. To learn more about the categories of third parties with whom we share such information, please see the “Purposes for which we process Personal Data” section of our Privacy Notice. We may share your information with trusted providers to perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries.
We do not disclose personal information of individuals we know to be under the age of 16 to business or third parties for monetary or other valuable consideration as a “sale” under California law.
13.3 Use of California Personal Information
For each of the above categories, we use the California Personal Information we collect for the business purposes disclosed within this Privacy Notice. For more information, please see the “Purposes for which we process Personal Data” section of our Privacy Notice. Note that the business purposes for which we may use your information include:
- Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
- Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same; •
- Debugging to identify and repair errors in our systems;
- Short-term, transient use including contextual customization of ads; and
- Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services. This includes:
- Delivering the services our customers have requested;
- Informing you of other products or services available from WebMD Ignite and its affiliates;
- Contacting you via surveys to conduct research about your opinion of current services or of potential new services that may be offered;
- Delivering customized content and advertising;
- Conducting internal research to develop and demonstrate technology; and
- Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide.
We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or purposes compatible with the context in which the California Personal Information was collected.
13.4 Your California Privacy Rights
If you are a California resident, you have certain rights related to your California Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law.
Right to Access/Know. You may request that we disclose to you:
- the categories of California Personal Information we have collected about you;
- the categories of sources from which the California Personal Information is collected;
- our business or commercial purpose for collecting or selling California Personal Information;
- the categories of third parties with whom we share California Personal Information; and
- the specific pieces of information we have collected about you.
To the extent that we sell your California Personal Information within the meaning of the California Consumer Privacy Act or disclose such information for a business purpose, you may request that we disclose to you:
- the categories of California Personal Information that we have collected about you;
- the categories of California Personal Information about you that we have sold within the meaning of the California Consumer Privacy Act and the categories of third parties to whom the California Personal Information was sold, by category or categories of personal information for each third party to whom the California personal information was sold; and
- the categories of California Personal Information about you that we disclosed for a business purpose.
Right to Delete. You have the right to request that we delete California Personal Information about you which we have collected from you.
Right to Opt-Out. You have the right to direct us not to sell your personal information at any time.
- To submit an opt-out request, click here: Do Not Sell My Personal Information or call us toll-free at the telephone number provided below.
- To opt-out from the sale of personal information for valuable consideration to analytics, social media, and advertising partners, please visit our Privacy Preferences Center.
You may request to exercise these rights by:
- Calling us toll-free at 800-332-2631
- Completing our rights request form available here
Residents of the State of California may also request a list of all third parties to whom we have disclosed certain personal information (as defined by California law) during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and would like such a list, please contact us via the “Contacting us” section provided above in our Privacy Notice.
See our CCPA Stats California Consumer Privacy Act Stats
As required under applicable law, please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide name, physical address, email address, contact information, and other information about your previous transactions with us. We may limit our response to your exercise of the above rights as permitted under applicable law.
Subject to applicable law, we may not discriminate against you because of your exercise of any of the above rights, or any other rights under the California Consumer Privacy Act, including by:
- Denying you goods or services;
- Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Providing you a different level or quality of goods or services; or
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Agent Authorization and Website Accessibility
Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may require verification of the agent’s authorization or require you to verify your own identity in response to a request even if you choose to use an agent.
If you use assistive technology and the format of this Privacy Notice interferes with your ability to access information, please contact us at 800-332-2631.