Effective Date: August 1, 2023
Date Last Updated: August 1, 2023
PRIVACY STATEMENT – YOUR PRIVACY RIGHTS
Thank you for your interest in Clinical Marketing Group, LLC (“CMG,” “we,” “us,” or “our”). We are committed to protecting the privacy of those with whom we interact. This Privacy Statement (“Statement”) contains details about how we collect, use, and share Personal Information about you (defined below) that we obtain from you when you interact with us via our website, email, mobile application, and in other online and offline interactions, and from other sources.
We collect Personal Information in several contexts as described below. However, this Statement does not apply to the following information:
Information about our employees, contractors, agents, and job applicants. Such information is subject to a separate privacy notice that we will make available to individuals.
Information we collect from individuals with whom we engage in solely business-to-business communications and transactions, such as information about the employees of our business partners and customers.
We may update this Statement from time to time. The current Statement will be effective when posted. Please check this Statement periodically for updates. If any of the changes are unacceptable to you, you should cease interacting with us. When required under applicable law, we will notify you of any changes to this Statement by posting an update on this website. When required under applicable law, we will seek affirmative consent from you before making material changes to the way we handle Personal Information previously collected from you. If you do not provide such consent, Personal Information will continue to be used in a manner that is consistent with the version of this Statement that was in effect when the information was collected.
2. Sources of Personal Information
We collect information about you and how you interact with us in several ways, including:
1. Information you provide to us directly. We collect information that you provide to us directly, such as when you register with us through our Services or you request healthcare referrals or other product through our Services.
2. Information automatically collected or inferred from your online interaction with us. We automatically collect technical information about your online interactions with us (such as IP address and browsing preferences).
3. Information from public sources, such as information from public records maintained by government entities, and information you submit in public forums.
4. Information from third parties. We receive information about you and your interactions with us from third parties, such as pharmacies, healthcare providers, insurance companies, credit reporting agencies , marketing and advertising providers, social network services, data brokers, and companies that provide or sell lists of potential purchasers. We also may receive information about you from friends and family members (such as other people insured under the same policy as you).
We may combine information that we receive from the various sources described in this Statement, including third party sources and public sources, and use or disclose it for the purposes identified below.
3. Types of Personal Information We Collect
The types of Personal Information that we may collect about you include:
1. Identifiers, such as your name, alias, postal address, country of residence, unique personal identifier, online identifier, internet protocol address, email address, user name, phone number, social media identifiers (e.g., Twitter handle, Instagram name, etc.), Social Security number, driver’s license number, or other similar identifiers, including identifiers for family members who may be involved directly or indirectly.
2. Customer records, such as your name, signature, address, telephone number, bank account number, credit card number, or other payment information.
3. Application and eligibility information for you and family members who may be requesting healthcare referrals, such as age, date of birth, gender, health status, disability, medical history, military or veteran status, date of birth, and financial and tax information (for government subsidies).
4. Commercial information and preferences, including product preferences, advertising preferences, products or services purchased, obtained, or considered, or other preferences or interests.
5. Internet or other electronic network activity information, such as your browsing history, search history, IP address, and information regarding your interactions with us (including interacting with us online, by the mobile application, and through advertisements).
6. Geolocation information, such as approximate location based on your IP address.
7. Audio, electronic, visual, or similar information, such as call center recordings, or customer support chat logs.
8. Professional or employment information, such as job title, employer, business address and contact information.
9. Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
4. How We Use Your Personal Information
We may use each category of your Personal Information described above in the following ways:
1. To enable interactions between you and us, such as to facilitate referrals, applications for, and purchases of our products; to register and administer your account, to support your interactions with us; to provide information about healthcare; to communicate with you about your health or our data practices; to install and configure changes and updates to programs and technologies related to interactions with us; to authenticate those who interact with us; and to respond to your requests, complaints, and inquiries.
2. For our own internal business purposes, such as to evaluate or audit the usage and performance of programs and technologies related to interactions with us; to evaluate and improve the quality of your interactions with us and the quality of programs and technologies related to interactions with us; to design new services and products; to process and catalog your responses to surveys or questionnaires (e.g., customer satisfaction reviews); to perform internal research for technological development and demonstration; to conduct data analysis and testing; and to maintain proper business records.
3. For legal, safety, or security reasons, such as to comply with laws and other legal requirements; to protect our safety, our property or the rights of those who interact with us, or others; and to detect, prevent, and respond to security incidents or other malicious, deceptive, fraudulent, or illegal activity.
4. In a de-identified, anonymized, or aggregated format. We may convert Personal Information into a de-identified, anonymized, or aggregated format, and use such information for any legal purpose.
5. For marketing. We may use your Personal Information to market our products or services. We may use your Personal Information to invite you to participate in marketing surveys, questionnaires, promotions, events or contests. We may audit aspects of our ad impressions. We may use your Personal Information for short-term transient use, including for contextual ad customization. We may use your Personal Information to enhance our content and to deliver advertisements to you, including in commercial emails. For more information about online marketing activity, see Section 6 below.
6. To fulfill other purposes disclosed at the time you provide Personal Information or otherwise where we are legally permitted or are required to do so.
7. For any other purposes for which you provide consent.
5. With Whom We Share Your Personal Information
We may share your Personal Information with the categories of recipients described below:
1. Healthcare related providers, services, products, and related entities: In order to provide you options with your healthcare request, we may share your information with healthcare organizations and similar entities.
3. Business partners: We may also provide your Personal Information or provide access to your Personal Information to our insurance companies on your behalf.
5. Organizations with which you have a relationship: We may disclose Personal information to an affinity group, employer, provider group, benefits administrator or consultant, healthcare system, pharmacy, financial services provider, or other entity with which you may have a relationship when such entity referred you to us or when you use our website or call center in connection with your relationship to such entity.
6. To others with your consent.
We may also de-identity, anonymize, or aggregate Personal Information to share with third parties for any purpose.
We also collect information, via cookies, web beacons, pixels, tags, or other tracking technologies, such as your Internet Service Provider and IP address, the date and time you access our website, the pages you access while visiting our website, and the Internet address from which you access our website. Some cookies exist only during a single session and some are persistent over multiple sessions over time. We use these technologies to remember user preferences, maximize the performance of our website and services, provide you with offers that may be of interest to you, measure the effectiveness of our email campaigns and to personalize online content. These cookies and other technologies may be used to track you across devices.
Some browsers have incorporated Do Not Track (“DNT”) preferences. Most of these features, when turned on, send signals to the website you are visiting that you do not wish to have information about your online searching and browsing activities collected and used. As there is not yet a common agreement about how to interpret DNT signals, we do not honor DNT signals from website browsers at this time. However, you may refuse or delete cookies. If you refuse or delete cookies, some of our website functionality may be impaired. If you change computers, devices, or browsers, or use multiple computers, devices, or browsers, and delete your cookies, you may need to repeat this process for each computer, device, or browser. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies.
7. Security and Retention
We maintain reasonable security procedures and technical and organizational measures to protect your Personal Information against accidental or unlawful destruction, loss, disclosure, access, alteration, or use. Nevertheless, transmission via the Internet and online digital storage are not completely secure and we do not guarantee the security of your information collected through the Service.
8. Children’s Privacy
Interactions with us are intended for individuals 16 years of age and older. Our interactions are not directed at, marketed to, nor intended for, children under 16 years of age. We do not knowingly collect any information, including Personal Information, from children under 16 years of age. If you believe that we have inadvertently collected Personal Information from a child under the age of 16, please contact us at the address below and we will use reasonable efforts to delete the child’s information from our databases.
9. Mobile Application
Our mobile application is intended to simplify the process of adding our business contact information. Our intention is to also provide greater accessibility and customer support through the use of a mobile application.
CMG Mobile application requests permission to access contacts for the purpose of adding CMG business contact information into the users contact section. Access to user's contact permission also provides CMG access to all contacts stored in the user's phone. CMG does not fetch contact details within the phone at any time. CMG mobile application assists user's with enabling features already located in their phone settings.
10. External Links
When interacting with us you may encounter links to external sites or other online services, including those embedded in third party advertisements or sponsored content which we do not control. We are not responsible for the privacy practices and data collection policies for such third party services. You should consult the privacy statements of those third party services for details.
11. Your Rights
Upon request, CMG will provide you with information about whether we hold any of your personal information. If your personal information changes, or if you otherwise want to correct, update, delete, or make other requests regarding your data (such as limiting sharing with non-affiliates), you may call us toll free at by mail at
Customer Service, ClinicalMarketingGroup.com
We will make reasonable efforts to respond to your request, but cannot guarantee that we will be able to honor your request. For example, we generally will retain your information for as long as your account is active, as needed to provide you services, or for other business purposes. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Please note that once your application has been submitted to your chosen health insurance company or any other relevant party (such as the federal government in the case of an application involving advanced premium tax credits) you may have to contact the insurance company or such other party directly to update your application and/or exercise your individual rights under HIPAA.
If you have questions regarding this Statement or our privacy practices, please contact us at:
Clinical Marketing Group, LLC.
To opt-out of receiving promotional email messages from us, please click on the “Unsubscribe” link contained at the bottom of each email or by contacting us using the information above. To opt-out of receiving satisfaction surveys and/or information on additional products and services from us, you may contact us at the information above. Please note that you will still receive communications from us regarding your insurance quote, application, policy or advanced premium tax credit even if you opt-out of receiving our surveys and/or notices of additional products or services.
14. Dispute Resolution
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
15. California Consumer Privacy Act
In very limited cases, we may collect information about certain California residents subject to the California Consumer Privacy Act (“CCPA”). However, this CCPA notice does not apply to the following information:
Any information provided in connection with seeking a financial product or service (including any data subject to the Gramm-Leach Bliley Act (“GLBA”) or the California Financial Information Privacy Act (“CalFIPA”)).
Information about individuals who are not California residents.
Information about our own employees, contractors, agents, and job applicants. Such information is subject to a separate privacy notice that we will make available to the applicable individuals.
Information we collect from individuals with whom we engage in solely business-to-business communications and transactions, including due diligence transactions, such as information about the employees of our business clients.
We collect limited personal information subject to the CCPA from data brokers. We use and disclose such information for our marketing and related operational purposes. We do not “sell” personal information as defined under the CCPA and we do not knowingly sell the personal information of minors under 16 years of age years of age. The following chart contains more detail about the categories of personal information we collect and disclose.
Subject to legal limitations and exceptions, California residents may exercise the following rights by using our website contact us page.
Right to Know. You have the right to request information about the categories of personal information we have collected about you, the categories of sources from which we collected the personal information, the purposes for collecting the personal information, and the categories of third parties with whom we have shared your personal information (“Categories Report”). You may also request information about the specific pieces of personal information we have collected about you (“Specific Pieces Report”).
Right to Delete. You have the right to request that we delete personal information that we have collected from you.
Do Not Sell: We do not “sell” personal information as defined under the CCPA.
Non-Discrimination: In accordance with applicable law, we will not discriminate against you for exercising these rights.
Verification: In order to exercise your rights, we may need to obtain information to locate you in our records, verify that you are a California resident, and/or verify your identity depending on the nature of the request. If you are submitting a request on behalf of a household, we may need to verify each member of the household in the manner set forth in this section.
Please be aware there might be circumstances where we will not honor you request, as permitted under the CCPA. For example, if we are not able to verify your identity and that you are a California resident, we may not honor your access or deletion request. Additionally, we may not delete your personal information if an exception under the CCPA applies to your deletion request. When making a request, you will be asked to provide your zip code, first and last name, date of birth, phone number (optional) and indicate how you would like to be contacted, which may require you provide contact information. You will also be required to attest that you are entitled to make the request.
We may request alternative information under certain circumstances and will inform you if such information is needed in the verification process.
Authorized Agents: Authorized agents may exercise rights on behalf of consumers, but we reserve the right to also verify the consumer directly as described above. Authorized agents must contact us by mail at the address provided above and include documentation demonstrating the agent has authority to exercise rights on the consumer’s behalf. At a minimum, we will require evidence of the agent’s identity, proof of registration with the California Secretary of State, and at least one of the following evidencing proof of your legal authority to act on the behalf of the individual consumer:
Written authorization signed by the Consumer; or
Certified copy of a Power of Attorney granted under Probate Code.
In the absence of any of the general conditions detailed above, we are entitled to reject any request submitted through an agent.
Timing: We will respond to Requests to Delete and Requests to Know within 45 calendar days, unless we need more time (in which case we will notify you), and may take up to 90 calendar days in total to respond to your request.
California Shine the Light: We do not share personal information subject to California Civil Code § 1798.83 (the “Shine the Light law”) with third parties for their direct marketing purpose.