Definitive Healthcare
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Populi Product Privacy Policy (the “Policy”)

Last updated July 1, 2024

Populi LLC (“Populi,” “we,” or “us”) is a subsidiary of Definitive Healthcare LLC, and provides the Populi product suite, including a business-to-business (B2B) market insights and analytics platform to healthcare providers. Populi helps payers and providers (collectively, “Customers”) get maximum value out of healthcare data with a more transparent and cost-effective business model that provides analytics through software as a service (SaaS). 

Populi customers with log in credentials will continue to access the Populi products at https://app.populi.ai/login. If you are a Customer, please note that your services agreement with Populi governs your use of the Populi products and services. By using Populi products and services (collectively, “Services”), you agree to the terms and conditions of this Policy. If you do not agree to the terms of this Policy, you should not use the Services and/or submit your Personal Information to us. 

Introduction

For the purpose of this Policy, “Personal Information” is information that identifies or relates to an identifiable individual. It may include information that is characterized as “Sensitive Personal Information” or “Sensitive Data.”

References to “you” and “your” mean any individual whose information we collect and process under this Policy.

This Policy explains how and for what purposes we collect and process:

(i)    Personal Information* about individuals represented and/or included in certain Populi products (“Consumers”). 
(ii)    Personal Information about authorized users/customer representatives who access and use the Populi Services (“Users”)

This Policy does not apply to:

  • Personal Information about individuals which we previously collected through our former website at Populi.ai governed by the former Populi website Privacy Policy here: https://populi.ai/privacy-policy/.
  • Information we collect which is not considered Personal Information; for example, where such information is deidentified, is not subject to existing privacy laws, or is subject to privacy laws but falls into an applicable exemption.
  • Collection of information by us which is expressly stated to be covered under other or different privacy notices such as, for example, employee-related data.
  • Collection or processing of information by other entities or service providers where Services are expressly offered under their own, separate, or different privacy policy(ies), including when you link to other websites and services from the Services. Such third-party websites may have their own privacy notices.

Information that we collect

We may collect the following categories of Personal Information about you in the following ways:

Where you are a Consumer (an individual whose Personal Information is included in our product):

  • We acquire or license Personal Information about Consumers from third party data providers/brokers. We do not collect Personal Information directly from consumers for use in our data products.
  • Categories of Personal Information we collect about Consumers may include: 
    • Personal identifiers and personal contact information such as name, postal address, and email address.
    • Education and employment information such as education level, employment status, and occupation category.
    • Personal characteristics such as age group, ethnicity, marital status, gender, military status, and whether you have had children.
    • Commercial information such as home ownership/rental status, household income bracket, and buying/activity interest.
    • Inferences about Consumers’ behavioral characteristics, drawn from Personal Information, such as likelihood indicators for certain lifestyle habits or preferences. 
    • Internet activity such as interest based on web site type or media preferences.
    • General geolocation information such as city, state, zip code, and geo tract code.
  • We may also collect deidentified data, which we license from third party providers and use for purposes including to build our propensity models. Deidentified data remains strictly deidentified and we do not attempt to reidentify it.

Where you are a Healthcare Provider:

We collect information about healthcare providers from publicly available sources for inclusion in our Provider Directory, which provides public information about individual providers and facilities.

Where you are a User (an employee or representative of a Customer, who has been authorized to access the Services on the Customer’s behalf): 

  • If you are authorized as a User, we may collect information about you directly from you and/or from the Customer, indirectly from you through your usage data, and from our affiliates.
  • We may collect Personal Information about you in order to create a credentialed User log-in for our Services. This may include:
    • your first and last name;
    • your business e-mail address; and
    • the password you create to access our Services.
  • We may additionally collect the following information about you as a User:
    • Usage data, including logins, gigabytes used, queries and dashboards accessed and other user behavior. We may also collect information through our Internet log files, which record data such as user IP addresses, browser types, and other statistical data involving the use of the Services This information may be used to analyze trends, to administer the Services, to monitor the use of the Services and to gather general demographic information. We may link this information to Personal Information for these and other purposes such as personalizing your experience and evaluating and improving the Services in general. For the purposes of platform use, customers have the option of providing to Populi in-network providers (NPI 1) and facilities (NPI 2), service area geographies (zips and states), and custom service line definitions (by CPT/HCPCS and ICD-10 codes). This information is only used within each customer’s environment and is not shared.
    • Information you submit us, including through the Services or directly to one of our customer success, technical or support representatives when you communicate with them though the Services or where you access our success portal.  If we receive a question for support, we collect and store the question as well as the answer to the question along with date/time and responses which are captured and stored. We may also collect aggregated statistics connected to support issues.
    • Information from and through our affiliates. Where your information comes to us directly from or via a corporate affiliate. *References in this notice to affiliates and corporate affiliates include our parent company Definitive Healthcare LLC and its wholly owned subsidiaries/group companies.
    • Information from Google Analytics and other cookies. We use Google BigQuery and Tableau Server to collect usage information from product users. We also use Google Analytics for usage analytics, as well as tag tracker to track usage behavior for the purpose of improving user experience and report on usage trends to our Customers. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here. We also use functional cookies through the product. These cookies store logged-in session information.

Purpose

We may use Personal Information about Consumers as follows: 

  • Use in our products. 
    • Identified Consumer Personal Information is included in our consumer analytics Population Intelligence product. 
    • Our clinical propensity models are created using deidentified/modeled data; however, we use identified data about individuals to create scores against our clinical propensity models.
  • License of data to our Customers. 
    • Identifiable Consumer Personal Information available through our Population Intelligence product is licensed to our Customers (usually hospitals) for direct-to-consumer marketing purposes, for defined geographies and number of records. 
    • We provide both de-identified and identified Consumer Personal Information within specific geographies, which is then licensed by our Customers for direct marketing (including direct to consumer marketing), audience segmentation and marketing planning purposes. 
    • Customers may, in their own CRM instances, match Consumer data with the data they already have. We do not make the link for the Customers, nor do we gain access to the Customers’ data.
  • Services to our Customers.
    • Audience segmentation and campaign management services: We may analyze Identifiable Consumer Personal Information to create audience lists and targeting criteria for our Customers’ review/use.  Upon our Customer’s instruction we may further assist with campaign management and activation by forwarding the chosen information to Customers’ preferred DSP/vendor. 


We may use User Information, including Personal Information, as follows:

  • For our legitimate business interests, including:
    • To provide you with the Services, such as giving Users access to the Services and administering User accounts.
    • To enhance, provide, support, and maintain our Services, such as supporting delivery of the Services, addressing service errors or technical issues, and contacting you for customer service purposes.
    • For analytics purposes and to improve the Services, including personalization and improvement of user experience to help us understand who uses the Services (and how). 
    • For internal operations such as operating and improving your user experience. We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Services as well as to provide a more customized, personalized, and enjoyable experience for users as well as to research, develop, test, and evaluate future product features and enhancements. 
    • To communicate with you, including where we respond to direct inquiries from our Users, through the Services, or with direct contact with one of our employees.
    • To tell you about changes to applicable terms and policies technical or other important updates. We may also use your information to let you know about changes to this Policy or other legal terms of relevance. We may contact you through email, by message or notice through the Services, or in any other manner as we see fit, to inform you about technical updates; service-related issues; and important changes to, and/or availability of, our Services. We can also contact you in this way regarding your safety and security when using the Services; to send you important security notices about potential fraud or security breaches; or to contact you to investigate a breach or suspected breach of our services contracts or security agreements. We may also reach out to you to find out more about your user experience and to improve our products. These communications are part of the Services, and you may not opt out of them.

How your information is disclosed

If you are a Consumer, your Personal Information may be disclosed to our Customers, as set out above, as well as to our affiliates and vendors. 

If you are a User, your Personal Information may also be disclosed to our affiliates and vendors but will not generally be disclosed to third party Customers. However, under the service contract of the Customer for which you are a User, individuals designated by the Customer may have the right to act as administrators and may therefore have the right to access information for all of that Customer’s Users for purposes of tracking Customer usage patterns as well as to delete User accounts at their discretion. If you have questions about who at your organization can delete or see your data, please contact your organization’s point of contact.

To the extent necessary, your Consumer or User information may also be disclosed to:

  • third parties, to fulfill your service requests;
  • business entities or individuals, who are involved where our parent company engages in a merger or other form of business asset transfer; or
  • law enforcement agencies, other governmental entities, or third parties as required by or permitted by law, in response to subpoenas or other court orders, or to exercise legal rights or defend against legal claims.

We may also share your information in a way that does not directly identify you, such as by sharing aggregate statistics about use of our Services with other companies. We may receive payment in exchange for such data.

How your information is protected

We use commercially reasonable administrative, technical, and physical security measures to protect the confidentiality, integrity, and accessibility of your information and to reduce reasonably foreseeable risks of harm resulting from loss, misuse, unauthorized access, disclosure, or modification. Except as outlined in this Policy, we restrict access to your Personal Information. However, no data transmission or storage can be guaranteed to be 100% secure. Accordingly, we cannot guarantee the security of any information you transmit through our Services, and you do so at your own risk.

Links to other websites/applications

The Services may contain links to websites operated by third parties that may contain their own privacy policies. To ensure your privacy is protected, it is recommended that you consult the privacy policies on any linked websites or applications. We are not responsible for the way in which others use your Personal Information or for any damage suffered as a result of viewing or visiting any third-party website or application. We also make no endorsement or representation regarding anything found on a third-party website or application.

Collection of information from children

Our Services are not intended for use by anyone under the age of 18. Further, we do not knowingly collect, use, or disclose the Personal Information of children under the age of 13. If you are under the age of 13 you should not provide any information to us. If you are a parent or guardian and believe that we may have collected information about a child under the age of 13, please contact us immediately using the information provided at the “Contact Us” section below so reasonable steps can be taken to remove that information.

U.S. State Supplemental Privacy Statement

For residents of any U.S. state with a Comprehensive State Privacy Law, please review our Populi U.S. State Supplemental Privacy Statement to learn more information, including how to exercise any rights you may have under applicable Comprehensive State Privacy Laws.

Data retention

We will retain your information as long as reasonably necessary for the purposes set out in this Privacy Policy, and in accordance with applicable laws. Further, we may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, or comply with law enforcement.

Contact us

Populi is committed to protecting the privacy of Consumers’ Personal Information and being transparent about our privacy practices. To exercise any opt-out or privacy rights you might be entitled to under applicable Comprehensive State Privacy Laws, please utilize the designated mechanisms provided in the Populi U.S. Supplemental Privacy Statement. For other questions, comments, or concerns about this Policy and/or our privacy practices, please contact us through the following methods:

E-mail: privacy@definitivehc.com

Phone: 1-866-679-6461

or write to us at:

492 Old Connecticut Path
Suite 401
Framingham, MA 01701
Attn: Populi Privacy Team

Changes to this Policy

We reserve the right to modify or amend this Policy at any time by posting the updated version and changing the date listed at the top of this Policy. Any material changes in how we use or share the information we collect, will only affect information collected after the posting of the updated Policy, unless otherwise expressly stated. You are bound by any revisions to this Policy and are encouraged to review this Policy periodically for updates.