Privacy Policy

This Privacy Policy is provided by Katon Partners LLC dba Katon Direct and our portfolio of affiliate brands and digital platforms (Adfire Health, TheScrubb and Live Recruit) that connect healthcare professionals with information to help make some of life’s most important decisions. As used herein, Katon Direct and its affiliate brands are referred to as “Katon Direct,” “us,” “we,” or “our.” For the purposes of this Privacy Policy, the websites, apps, and products provided by Katon Direct that link to this Privacy Policy will be referred to as the “Services.”
This Privacy Policy describes the types of personal information that we may collect about you; how we use, protect, and share that information; and the choices that you have. This Policy only applies to the specific Services that link to it. By using the Services, you acknowledge the information collection practices and purposes outlined in this Privacy Policy. Any capitalized terms used, but not defined, in this Privacy Policy have the meanings provided in the Terms of Use of the applicable Services.
1. Information We Collect

Information collected directly from you:

  • Form Submission. Your name, email, phone number, NPI number, profession,  and other relevant information when you submit the form on our landing page.
  • Mailing List. If you sign up for one of our mailing lists, we collect your email address and/or postal address. We use this information for our direct marketing purposes.
  • Partner Promotion. If you provide personal information to us in response to a promotion sponsored by one of our business partners, we collect any personal information that you may choose to provide to us, such as name, contact information, or professional information. We may disclose your personal information to the third-party partner described in the promotion, and the third-party partner may use your personal information for their direct marketing purposes.

Information collected automatically:

  • E–mail Interconnectivity. If you receive email from us, we may use tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. We use this information to understand how you interact with our communications to you, to measure the effectiveness of our marketing efforts, and for analytics purposes.
  • Mobile Devices (such as Phones, Tablets, Connected TVs, Gaming Consoles, and Other Digital Media Streaming Devices). If you use or access any of our Services on a mobile device, we may collect information from your mobile device, such as device ID, hardware ID, IP Address, and other unique identifiers. We use this information for data analytics purposes and to optimize our services (for example, to identify unique visitors and understand how users interact with us on their devices).
  • Website Interactions. When you visit a website or landing page that links to this Privacy Policy, we may automatically collect information about how you interact with that website or landing page (e.g., session replay). This may include which links you click on or information that you type into our online forms. This may also include information about your device or browser. We use this information to understand how you interact with our Services so we can improve them, and to remember and/or understand your preferences and interests in order to select offerings that you might find most useful. We also have a business need to secure our Services and detect and prevent fraud.
  • Location Data. When you use certain of our Services, we may solicit your permission to collect your location data. Some features within our Services (such as location-based offers) may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data. The specificity of the location data may depend on several factors, including the device you are using and how you are connected to the Internet. If you enable location services for our Services, we may collect location data periodically as you use or leave open our Services. Depending on the platform you use to access our Services (e.g., Apple’s iOS, Google’s Android) you may be able to control whether location data is collected by adjusting your device settings.
  • Cookies and Other Internet Technologies. We and our service providers operating on our behalf may automatically collect or receive certain information associated with you and/or your device(s) as part of your use of the Services through device-based tracking technologies such as cookies, pixels, tags, beacons, scripts or other technology. The information we collect through the use of these technologies may include your browser type, operating system, Internet Protocol (IP) address, domain name, click-activity, referring website, date/time of visit, and geolocation data (such as information that identifies the precise location of your mobile device when you agree to allow an app or Service to collect this). We use this information to make our Services operate efficiently, for analytics purposes, to optimize your user experience, to detect and prevent fraud, and to provide you with the ability to save your preferences such as login and preferred language.  We may also use this information for the purpose of behavior-based advertising, so that we can provide more relevant and personalized digital advertisements to you and measure the effectiveness of our digital advertising efforts.
  • Cross-Device Tracking. We and our service providers may collect and store information about users’ interactions with unaffiliated websites and applications through the use of technologies that allow us to infer the presence of a common user or household behind multiple devices or browsers, for instance, and then link those browsers and devices into a device graph. We use this information to remember your preferences across devices, detect and prevent against fraud, optimize the Services for you, and provide personalized advertising to you.
2. How We Use Your Information
In addition to the purposes and uses described elsewhere in this policy, we may use your personal information in the following ways:
  • To identify you when you engage with us and our Services.
  • To make our Services available to you and to fulfill our contractual obligations to you (such as completing orders that you place or delivering Services that you requested).
  • To communicate with you about our Services (e.g., about your application or submission) or to respond to inquiries related to support, employment opportunities, or other requests.
  • To deliver marketing and promotional materials related to our Services in accordance with applicable laws, including information relating to our products, services, sales, marketing research or promotions.
  • To provide you with personalized advertising on our Services based on your online activity. We use your personal information to show you relevant interest-based advertising, measure the effectiveness and reach of advertisements and services, verify delivery and track performance of an advertising campaign, and ensure that an ad is only delivered when a real person is visiting the site and that the same users don’t see the same ads too frequently.
  • To monitor, improve, and conduct analytics on our Services and advertiser product offerings.
  • For internal administrative purposes, such as safety and security of our Services, and to manage our user relationships.
  • To detect security incidents, and to protect against malicious, deceptive, fraudulent, or illegal activity, including attempts to manipulate or violate our policies, procedures, and terms and conditions.
  • To comply with legal obligations, to establish or exercise our rights, to defend against a legal claim, and to investigate, prevent, or take action regarding possible misconduct.
  • For such other purposes not described in this Privacy Policy if we have obtained your prior consent or as otherwise permitted by law.
In many situations we have more than one purpose for the use of your personal information. If we need to use your personal information for purposes not listed here, we will obtain your prior consent before using your personal information for those additional purposes.
3. How We Share Your Information
In addition to the specific situations discussed elsewhere in this policy, we may disclose your personal information in the following situations:
  • Affiliates and acquisitions. We may share your personal information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share your personal information with that company using appropriate safeguards, including at the negotiation stage.
  • Our business clients. When we collect and process information on behalf of our business clients, we share that information with those clients.
  • Service providers. We share your information with service providers who help us operate our business and perform services on our behalf. Among other things, service providers may help us to administer our website, conduct surveys, provide technical support, assist or support our business operations and other administrative functions, process payments, and assist in the fulfillment of orders. For example, we use Google Analytics to monitor the use of some of our Services. For further information about how Google may use data it collects through our Services you may click here. You also may choose to install the Google Analytics Opt-Out Browser Add-on to opt out of Google Analytics data collection.
  • Audience measurement services. We may share your personal information with audience measurement companies that help us and other websites measure and understand the audiences that view our content.
  • Aggregated and anonymous information. We may share aggregated, anonymous information with any third party. This information is not linked to personal information that can identify you or another individual person.
  • Advertising. We may share certain data with advertising platforms, such as The Trade Desk and Google and social networks such as Twitter, Facebook, LinkedIn and Snapchat to allow us and third parties to target existing users and customers with highly relevant advertising campaigns. For the purposes of such campaigns, we may share a unique code (such as a hashed email address) with the applicable advertising platform to identify potentially relevant audiences for targeted advertising. We use services such as Google Ads’ Customer Match, LinkedIn Matched Audiences, LiveRamp, and Facebook Custom Audiences for these purposes.
  • Other persons or entities with your consent. With your consent (when required), we may share your personal information with our third party marketing partners, and they may contact you by email, telephone, postal mail or other common communication methods with marketing and promotional messages about their products or services. If you consent to receiving communications from a third party advertiser, your personal information will be subject to that third party’s privacy policy. From time to time, we may ask if you would like us to share your information with other third parties that are not described elsewhere in this Privacy Policy, and we will obtain your consent (if required by applicable law) before sharing your personal information with those third parties.
  • Other disclosures without your consent. We may disclose your personal information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
Some of our Services may provide the opportunity to post publicly-viewable comments, content, or reviews. If you decide to submit information to publicly accessible areas of our Services, you do so with the understanding that we have no control over what happens to your information or who may be able to access it once you share it publicly.
4. Data Retention and Security
We retain your personal information according to applicable laws or regulatory requirements and keep it as long as is necessary to fulfill the purposes described in this Privacy Policy or for which the personal data was collected.
While no online service is 100% secure, we work to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks, and we use a variety of security technologies and organizational procedures to help protect your personal data from unauthorized access, use, or disclosure. We also limit access to your personal information to those personnel with a need to know in order to perform job duties for us.
5. Your Rights and Controlling Your Information
  • Choice and consent: By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this Privacy Policy.   You are not required to provide personal information to us, however, if you do not, it may affect your use of the Services, and we may be unable to provide the Services to you.
  • Control: You may choose to opt out of interest-based advertising by visiting https://optout.networkadvertising.org/ or https://optout.aboutads.info/, or by setting your browser to restrict or delete cookies. If you have previously agreed to us using your personal information for direct marketing purposes, you may also change your mind at any time by contacting us using the contact information below.
  • Access and correction: If you need to access or correct any information we have about you, please contact us using the contact information below. We will endeavor to provide you with information about the personal information we have about you, and we will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
  • Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
  • Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
  • Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out link provided in the communication.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using any of the methods provided in Section 9 (“Contact information”) above.
Do Not Track
We are committed to providing you with meaningful choices about the information we collect on the Services, and that is why we provide the access and control choices set forth in this Privacy Policy. However, we do not recognize or respond to browser-initiated Do Not Track (“DNT”) signals, in part because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators, nor is there a consistent standard of interpreting user intent.
6. Third-party Links
Our Services may link to third-party sites and services that are not operated by us. Please be aware that we have no control over the content and policies of those third-party services, and cannot accept responsibility or liability for their respective privacy practices.
7. Children’s Privacy
Our Services are not intended for anyone under the age of 18, and we do not knowingly collect personal information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal information, please notify us promptly, and we will take steps to delete that information.
8. Changes to this Policy
At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our Services. Your continued use of our Services after any changes to this Policy will be regarded as acceptance of our practices around privacy and personal information.
9. Contact Information

To exercise any of your data privacy rights, you may contact us using the information provided below:
Telephone: 914-921-8800
Email: sayhello@katondirect.com
Mail:
KatonDirect
2 Landmark Square
Stamford, CT 06901
Attn: Katon Direct – Privacy Officer

10. California Privacy Notice
This California Privacy Notice only applies to residents in the State of California (“consumers”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.
Information We Collect
We have collected the following categories of personal information from consumers within the last twelve (12) months:
  • Identifiers (such as name, postal address, online identifier, IP address, email address, or other similar identifiers)
  • Customer records information (such as financial information)
  • Commercial information (such as records of products or services purchased, obtained, or considered)
  • Internet or other similar network activity (such as browsing history, information on your interactions with our website, application or advertisements)
  • Geolocation data
  • Professional or employment-related information (such as current or past job history)
  • Inferences (such as a profile reflecting your preferences, characteristics, behavior, attitudes, or abilities)
We obtained the categories of personal information listed above from the categories of sources listed in Section 1 (“Information We Collect”) above.
Uses of Personal Information
We may use or disclose the personal information we collect for one or more of the purposes listed in 2 (“How We Use Your Information”) above.
Sharing Personal Information
We may share your personal information with the categories of third parties listed in Section 3 (“How We Share Your Information”) above. We do not sell personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability

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 (the “right to know”). Once we receive your request and confirm your identity, 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.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing sales, if any, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, if any, identifying the personal information categories that each category of recipient obtained.
  • The specific pieces of personal information we collected about you (also called a data portability request).
Right to Delete
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 (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
  1. 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please contact us using one of the contact methods listed above. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may only submit a request to know twice within a 12-month period. Your request to know or delete must provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information or an authorized representative. 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. 

 

Any disclosures we provide will only cover the 12-month period preceding our receipt of your 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; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.