WebMD Health Services Group, Inc.

Privacy Policy

WebMD Health Services Group, Inc. recognizes the importance of your privacy. This Privacy Policy describes the privacy practices for www.webmdhealthservices.com (the “Site”), which is operated by WebMD Health Services Group, Inc. (“WebMD,” “we” or ”us”). We refer to the Site, along with the information and services made available to users of the Site, as the “Services.” We urge you to read this Privacy Policy carefully.

This Site provides general information about the products and services provided by WebMD. However, if you are an employee or health plan member of an employer or health plan that has contracted with WebMD to provide you with access to an online wellbeing portal, and you have registered to access that portal, the privacy policy available on that portal applies to that website. If you do not want us to collect, use or share information about you and your use of the Services as described in this Privacy Policy, then you should not use the Services. By using the Services, you acknowledge that we will store, use and otherwise process your information in the United States where we are located.

Information Collected

Information about your use of the Services is collected as follows:

Registration

While you may use certain Services without registering, a number of the Services do require that you register with WebMD for them to function properly. If you choose to register or update an existing account with WebMD or access certain Services, you may be required to provide personal information, such as your name, company, job title, telephone number, and email address, and a username and password to access your WebMD account. You are responsible for ensuring the accuracy of the personal information that you submit to WebMD You may choose to update or supplement the personal information that you provided at registration at any time through your account settings.

Services Information

We automatically collect and store information about your use of the Services, such as your engagement with particular content, whether you opened a particular email, clicked on a link and how often and when you engage with the Services. We also collect information about your device when you access the Services including IP address, cookie information and advertising ID (which is a unique, user-resettable identification number for advertising associated with a mobile device), all of which may be associated with information we have about your use of the Services. We use cookie and other tracking technologies, such as pixels, tags, web beacons and software development kits to collect the information about your use of the Services and your device. If you are registered with the Site, we may elect to associate this information with your registration information.

Market Research

You may participate in market research surveys conducted by us or on our behalf for our own internal business purposes. For some surveys, you may be asked to provide personal information for re-contact or payment fulfillment purposes.

Information Forms

From time to time we may offer you the opportunity to receive additional information or services from us. If you wish to receive such information or services, you may be asked to provide personal information to fulfill the request. Unless otherwise specified in the request form, we may use such information as described in this Privacy Policy.

Non-registered Users

Even if you have not registered with the Site, we collect information about your use of the Services through the use of cookies and other tracking technologies. The information we collect includes the referring website, if applicable, the type of browser you use, the content viewed, and the time and date that you accessed the Services.

 

How Your Information May be Used

Information about your use of the Services may be used as follows:

Provision of the Services

We may use the information collected about you to provide, evaluate, optimize and improve the Services, develop new Services and for research, analysis and reporting purposes.

Communications

We may use your registration information and other information that we collect about you, as described in this Privacy Policy, to send you communications. By registering, you are consenting to receive these communications.

Business Relationship

We may use your information to manage and administer our relationship with you, your company or organization including keeping records about business contacts and content of interest to you so we can customize our offering for you, develop our relationship and target our marketing and promotional campaigns.

Third Parties

WebMD may contract with third parties, including ad servers, ad agencies and ad technology vendors to help deliver advertising about our Services on third party websites, to analyze the performance and effectiveness of advertising and provide associated reporting to WebMD. We may also engage third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them on third party websites.

Member Profiles

We may associate information that we have collected about your use of the Services with personal information you have provided to us, thereby creating a profile of you that we may update from time to time, as further described below.

Account Management

We may use your information to administer your account, respond to your inquiries, fulfill your requests and send you administrative communications about the Services.

Fraud Detection

We may use information about use of the Services to detect and defend against fraudulent, abusive or unlawful activity.

Sharing Your Information With Third Parties

Information about your use of the Services may be shared as follows:

Companies and Contractors Who Work for Us

We work with third party companies and contractors to help us provide the Services and to otherwise assist us in the operation of our businesses, including in the areas of email management and deployment, analytics, marketing, advertising, market research, hosting online events such as webinars, and customer service. We may provide these companies and contractors with personal information about users of our Services so that they can fulfill their responsibilities to us, however, we do require that they agree to limit their use of this personal information to the fulfillment of these responsibilities.

Advertising

While we do not permit third parties to serve you advertisements on the Site, WebMD and/or certain third parties may collect information about you for online behavioral advertising purposes in order for you to receive relevant interest-based advertising about WebMD and the Services on third party websites, platforms and media channels, through the use of cookies and other tracking technologies. Please see our Cookie Policy for more information.

Consent

We may disclose your personal information to a third party in a manner not addressed by this Privacy Policy subject to your consent at such time.

Aggregated Information

We may provide aggregated information about users of our Services to third parties as we deem appropriate in our sole discretion.

Social Widgets

We may include social widgets on the Site which enable you to interact with the associated social media services. These widgets may collect browsing data which may be received by the third party that provided the widget, and are controlled by these third parties. You may be able to manage your privacy preferences directly with the applicable social network platform.

Business Transfers

If we transfer a business unit (such as a subsidiary) or an asset (such as a website) to another company, that company will be required to treat any personal information collected under this Privacy Policy consistent with the applicable terms of this Privacy Policy.

Legal Requirements

We may release personal information when we believe release (i) is required to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order and to meet national security or law enforcement requirements; or (ii) is reasonable in response to a physical threat to you or others, to protect property or defend or assert legal rights of us or others.

 

Security of Information

We have implemented appropriate technical and organizational security measures to protect the personal information that we have under our control from unauthorized access, use and disclosure and accidental loss. You are solely responsible for maintaining the security and confidentiality of your account username and password. Unfortunately, no method of transmission over the internet or method of electronic storage is completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.

 

Choice and Control

Account Information

You can correct, update or review personal information you have previously submitted by going back to the specific Service, logging-in and making the desired change. You can also update any personal information you have submitted by contacting us using the contact information listed below. If you have registered and desire to delete any of your registration information you have provided to us from our systems please contact us using the contact information listed below. Upon your request, we will delete your registration information from our active databases and where feasible from our back-up media. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to the WebMD Sites from our servers.

Cookies

Most browser software can be set to reject all cookies, including third party cookies, however, if you choose to reject our cookies, your ability to access and use the Services will be limited. Refer to our Cookie Policy for additional information about opting out of cookies.

Email Communications

If you no longer wish to receive a particular type of email communication from us, you may unsubscribe by clicking the “unsubscribe” link located at the bottom of the email and following the instructions. Also, if you have provided us more than one email address, we may continue to contact you using the other email address not associated with the emails from which you have unsubscribed, until you unsubscribe from emails sent to that other address.

California Privacy Rights

This section is provided pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”) and other applicable California privacy laws. This section applies solely to our users who are California residents as defined under applicable California privacy laws.

Information We Collect

Within the last twelve (12) months, we have or may have collected the following categories of information from our users and/or consumers: identifiers; personal information listed under Cal. Civ. Code § 1798.80(e); protected classification characteristics under California or federal law; biometric information; internet or other similar network activity; geolocation data; professional or employment-related information; and inferences drawn from any of the information identified in this section.

Categories of Sources from Which Information is Collected

As described in the “Information Collected” section above, we obtain the categories of personal information listed above from the following categories of sources:

• directly from you; and
• directly and indirectly through cookies and other technologies.

Using and Sharing of Personal Information

The personal information described in the categories above may be used for the business purposes listed in the “How Your Information May be Used” section above.

We disclose your personal information for a business purpose to the following categories of third parties: (a) service providers and (b) third parties to whom you authorize or direct us to disclose your personal information in connection with the Services. In the preceding twelve (12) months, we have disclosed the personal information described in the categories listed above for the business purposes listed above in the “Sharing Your Information With Third Parties” section above. We may also share your personal information for any other purpose(s) disclosed to you at the time we collect your information or with your consent.

Personal Information “Sold” to Third Parties

In the preceding twelve (12) months, we have not sold your personal information to third parties. 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 under the CCPA

As of January 1, 2020, California residents, as defined under the CCPA, may take advantage of the following rights:

• You may request, up to two (2) times each year, that we disclose to you, once we receive and confirm your verifiable consumer request, the: (1) categories and specific pieces of personal information that we have collected about you; (2) categories of sources from which your personal information is collected; (3) business or commercial purpose for collecting your personal information; (4) categories of personal information that we disclosed for a business purpose; (5) categories of personal information that we sold about you; (6) categories of third-parties with whom we have shared your personal information; and (7) business or commercial purpose for selling your personal information.

• Subject to certain exceptions and up to two (2) times each year, you may request that we delete any of your personal information that we collected from you. Once we receive and confirmed your verifiable consumer request for deletion, we will delete (and direct our service providers to delete) such personal information from our records, unless an exception applies.

To exercise the access and deletion rights described above, please contact us at:
WebMD Health Services Group, Inc.
Attn: Privacy Office
9229 Delegates Row, Suite 400
Indianapolis, IN 46240
privacy@webmd.com

You will be asked to provide certain identifying information, such as your name, email, and residency. While processing your request, we may ask you to provide further verifying documentation. We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request. 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.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA. Accordingly, and unless permitted by the CCPA, we will not: deny you services; charge you different prices or rates for services; provide you a different level of service; or suggest that you may receive a different price or rate for services or a different level for services. We may charge a different price or rate or provide a different level of service if the difference is reasonably related to the value provided by your personal information.

Other Applicable California Privacy Laws

Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your personal information with third parties. If you reside in California and have provided your personal information to us, you may request information about our disclosures of certain categories of personal information to third parties for direct marketing purposes in the preceding calendar year. You can submit such request by sending an email by using the Contact Us link at the bottom of every page of the Site.

Children

We are committed to protecting the privacy of children. The Site is not designed or intended to attract children under the age of 18. The Site does not collect personal information from any person we actually know is under the age of 18.

 

Note to Users Outside of the United States

WebMD 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 Visitors from the European Economic Area (EEA) and the UK

The EU General Data Protection Regulation and UK General Data Protection Regulation (together the “GDPR”) require certain information to be provided to data subjects located in the EEA and the UK, and grant them certain rights regarding their personal information. This section applies solely to the processing activities that are governed by the GDPR.

Data Controller and EEA Representative

WebMD is will be the controller of the personal information provided to, collected by or for, or processed in relation with, the Site and Services. WebMD has appointed Aptus Health International France SAS as its representative in the EEA. WebMD’s Data Protection Officer can be contacted at privacy@webmd.com.

Legal Bases for Processing

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 necessary to perform a contract with you to deliver the Services that you have requested, or to take certain steps prior to entering into such contract. Additionally, we may also process your information based on our legitimate interest: (i) in keeping the Site and Services safe and secure; (ii) in complying with a legal obligation such as a law, regulation, search warrant, subpoena, or court order, (iii) in exercising or defending legal claims; and (iv) where necessary to protect our vital interests, or those of others. Lastly, we may also process your information when you have consented to such processing, particularly when you have consented to receiving certain content and advertising.

Where we rely on your consent to process your personal information, you have the right to decline consent or withdraw your consent at any time. Where we rely on our legitimate interests to process your personal information, you have the right to object.

Your Rights Under the GDPR

If you are a WebMD 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 (including, in limited circumstances, the right to ask us to stop processing your personal information, with some exceptions, by contacting us); 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 WebMD 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 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 WebMD and you no longer want us to use your personal information to provide the Services to you, you may close your account.

Transfers Outside the EEA and the UK

We are located in the United States. Accordingly, as the controller, we process your personal information in the United States. We may also transfer your personal information outside the United States to service providers with operations in other countries. For more information, please refer to the “Note to Users Outside of the United States” section above.

Automated Decision Making

We do not make automated decisions that create legal effects or otherwise significantly affect you.

Contacting WebMD About Your Personal Information or Privacy

Please send us an email by using the Contact Us link at the bottom of every page of our Site if you have any questions about this Privacy Policy or the Personal Information we maintain about you.

You can also contact WebMD’s Privacy Office at:

WebMD Health Services Group, Inc.
Attn: Privacy Office
9229 Delegates Row, Suite 400
Indianapolis, IN 46240
privacy@webmd.com

Changes to This Privacy Policy

We reserve the right to change or modify this Privacy Policy or any of our tools or 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 policy we will notify you by email (sent to the email address specified when you register) and/or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this Site 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 Site or the Services. Please exit the Site immediately if you do not agree to the terms of this Privacy Policy.

Updated: May 14, 2021

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