Privacy Policy

Last updated: May 29, 2021

This Privacy Policy describes how TheScrubb (“we”, “us”, or “our”) collects and uses personal information about you when you visit this website (www.thescrubb.com) (the “Site”), access or purchase any of the services or products offered by TheScrubb, or subscribe to any communications from us (collectively, the “Services”). More specifically, this Privacy Policy describes the types of personal information that we may collect; how we use, protect, and share that information; and the choices that you have. By using the Services, you acknowledge and agree to 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.

TheScrubb is owned and operated by Katon Partners LLC d/b/a Katon Direct (“Katon Direct”), and its affiliate brands include Adfire Health and Live Recruit. The personal information you share with TheScrubb may be shared with and processed by Katon Direct and any of its affiliate brands in accordance with this Privacy Policy.  

This Privacy Policy also incorporates our Cookie Policy. To learn more about how we use cookies, web beacons, and other technologies on our Services, please read our Cookie Policy. By agreeing to this Privacy Policy, you are also agreeing to our Cookie Policy. 

1. Information we collect

Information you voluntarily provide to us: 

  • When you register for an account. When you register for an account on our Site or subscribe to communications from us, you provide us with identifiers (such as your name, email, phone number, and NPI number), professional information (such as your employer, practice area, or job title), and any other relevant information that you choose to share with us. If you connect a third-party service to your account with TheScrubb (e.g., LinkedIn, Facebook, or Google), we may be able to see your profile and other information shared by that third-party platform. We collect this information to register your account, provide the Services to you, save your preferences, personalize the Services based on your interests, improve and optimize the Services, and remember your transaction history.
  • When you share your content with us. Some features of the Services may allow you to submit, post, or publish your content or information to the Services. We may collect any personal information that you provide, including your username, comments, likes, interests, status, pictures, and references to your online activity. 
  • When you provide feedback or request customer support. If you provide feedback to us or contact us for customer support, we may collect your name and email address, as well as any other content that you send to us. We use this information to respond to your request, provide and improve the Services, and improve your customer experience. 
  • When you subscribe to our mailing list. If you sign up for one of our mailing lists, we collect identifiers such as your name, email address, and/or postal address. We use this personal information to provide you with the Services that you request . 
  • When you participate in partner promotions. From time to time, we and our affiliates may offer sponsored content, events, or other promotions in collaboration with a third-party partner. We may collect personal information such as your name, email address, or other contact information, and any other personal information that you may choose to provide as part of the promotion. We use this information to contact you about the promotion, and we may share this information with our third-party promotion partner.  
  • When you respond to surveys. When you participate in a survey, we collect information that you provide through the survey. We use your personal information to manage and improve our Services, improve your customer experience, and for any other purposes that we notify you about when you complete the survey. 

 

Information collected automatically:  

  •  Based on email communications. If you receive email from us, we may use tools to automatically capture data related to your interaction with the email, such as when you open our message, click on any links or banners it contains, and make purchases. We use this information to improve our marketing campaigns, understand how you use our Services, and optimize our communications with you. Please refer to our Cookies section below to learn more about how we use tools, such as cookies, pixels, and web beacons.
  • From your mobile device. If you access the Services using a mobile device (such as a connected TV, mobile phone, or tablet), we may automatically collect information from your device, including identifiers such as the unique identifying information broadcast from your device, your IP address, or geolocation information. We use this information to improve the Services and your user experience. 
  • When you access the Site. When you visit or access our Site, we automatically collect Internet and electronic network activity information to understand how you interact with our website (e.g., links you click on, your IP address, time of visit, referring URL, or information that you type into our online forms, and other information about your device or browser). (Please refer to our Cookie Policy to learn more about the tools we use to collect information about your website interactions.) We use this information to understand how you interact with our Site, to improve our Services, to understand your preferences and interests in order to select offerings that you might find most useful; and to detect and prevent fraud on our Services.  We may also use certain web analytics services, including third-party services such as Google Analytics, to help us understand and analyze how visitors use our Services, such as which pages you visited and what actions you took. We may receive reports based on the use of these technologies on both an individual and aggregated basis. These analytics services, including Google Analytics, may also use this information to place advertisements for our products on other websites that you visit after you use the Site. For further information about how Google may use data it collects through the Site 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.  
  • When you access location-based Services. Some of our Services (such as location-based offers) may only function upon confirmation of your location. When you use these Services, we may solicit your permission to collect your location data. If you choose not to allow access to your geolocation information, some features of the Services will not be available or may not function properly. 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. To revoke your permission to access your location information, please adjust the permissions settings on your device.
  • Across websites and applications. We, third-party advertising partners, and our service providers may collect and store information about your interactions over time and across unaffiliated websites and applications. This information is used 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 so that we can understand your use of our Services across devices, improve your user experience, and personalize the Services for you. 

 

Information we may collect from other sources: 

  • Our affiliates. We may receive your data across our different Services and affiliated entities, and we may combine information internally across our different Services to improve our Services and your user experience. 
  • Other users. Sometimes, a friend may refer us to you or provide information about you to us, for example, if your friend signs you up for our newsletter. If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us. We may use this information to make our Services available to you at your friend’s request. If your friend did not have permission to share your personal information with us, please contact us promptly to request deletion of your information from our database. 
  • Your company or employer. If your company or employer provides us with personal information about you in connection with our business relationship, we may collect identifiers (such as your name, e-mail, address and/or phone number) or professional information (such as your job title or company name). We use this information to perform our contractual obligations to you and/or your employer, to provide the Services, and to communicate with you about new features or updates to the Services. 
  • Publiclyavailable data. If you publicly share your personal information, or if your personal information is otherwise publicly accessible, we may collect that personal information and link it to information that we already have about you. We may use this information to improve your user experience while accessing our Services.  

 

Social media platforms and other third-party services. Some of our Services may include features that are designed to interact with social media platforms and other third-party services (e.g., Facebook, Twitter, Instagram, and loyalty programs). If you access the Services using one of these social media platforms or authorize us to access your personal information via these third-party services, we may receive information about you from those third-parties, such as account and profile data, and we may combine this data with information we already have about you.  We may also collect information about you through interactive applications (e.g., mobile devices, third party social networking services, and embedded audio and video players), from co-branded partners and websites (e.g., on our Facebook pages), from our advertisers, and from commercially available sources (e.g., data aggregators and public databases). We use this information to improve our Services and to personalize the advertising and marketing we direct to you. Please note that this Privacy Policy does not cover the privacy practices of third parties, including those that may disclose information to us. If you have concerns or questions about how a third party is using or disclosing your personal information, you must contact that third party directly.

2. How We Use Your Personal Information

In addition to the purposes and uses described elsewhere in this policy, we may use your personal information in the following ways:

  • To make our Services available to you and to identify you when you engage with us and our Services.
  • To provide content recommendations based on your interactions and interests.
  • To process transactions associated with your use of Services for which there is a charge, including to process payments and verify your identity or payment information for your security and protection.
  • To communicate with you about your account, your purchases or orders, or updates to our Terms of Service, and to respond to inquiries related to support, employment opportunities, or other requests.
  • To deliver direct 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 the information we have to improve our advertising systems so we can 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 relationships with our users.
  • To permit you to participate in social sharing, including live social media feeds and to implement social features you choose to use.
  • To detect security incidents, and 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 as you may consent (from time to time) and as otherwise permitted by law.

 

In many situations, we have more than one purpose for collecting your information.

3. How We Share Your Information

In addition to the specific situations discussed elsewhere in this policy, we may disclose your personal information to the following parties:

  • Affiliates. 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). We ensure our affiliates abide by the terms of this Privacy Policy. 
  • Our clients. In some cases, we may act as a service provider to our clients when we collect personal information from you. We share that information with those clients. The personal information that a client collects about you will be subject to that client’s privacy policy, and you must contact the client directly if you need to access or exercise any relevant data subject rights with respect to the personal information the client has about you. 
  • Service providers. We share your information with our service providers who 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, measure and understand the audiences that view our content, and assist in the fulfillment of orders. 
  • 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.
  • Third-party advertisers, platforms, and vendors. We may share certain data with advertising companies, platforms, and analytics partners, such as The Trade Desk and Google, or social media networks, such as Twitter, Facebook, LinkedIn and Snapchat. We share your personal information with these third parties to allow us to target existing users and customers with highly relevant advertising campaigns on our behalf and on behalf of our clients. For the purposes of such campaigns, we may share a unique code (such as a hashed email address) with the applicable advertiser or advertising platform in order for that identifier to be matched against existing users of the relevant platform and 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. Some advertising platforms will allow you to opt-out of the use of your personal information for targeted advertising purposes, and you should review your account settings on the relevant platform if you do not want the platform to use your personal information to personalize advertising to you. You can also opt out of our use of your personal information for targeted advertising purposes by emailing us at: sayhello@thescrubb.com.   
  • Mergers and reorganizations. If another company acquires, or plans to acquire, our company, business, or our assets, we may share your personal information with that company using appropriate safeguards, including at the negotiation stage. 
  • Other parties with your consent. With appropriate consent when required, we may share your personal information with unaffiliated third parties, such as our marketing or advertising 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. When you provide consent to receive communications from a third-party partner, your personal information will be managed by that third party’s own privacy policy. 
  • Law enforcement, government agencies, and courts. We may disclose 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.

4. International Transfers of Personal Information

The personal information we collect is stored and processed in the United States, and where we or our partners, affiliates, and third-party service providers maintain facilities. This means your personal information may be collected in or transferred to a jurisdiction with different data protection laws less protective than your home country. By providing us with your personal information, you consent to the disclosure to these overseas third parties.

5. 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 information 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 information 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.

6. Your Rights and Choices

By providing personal information to us, you agree 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. The following choices and rights are available to you:

  • Consent management settings: Your account settings on TheScrubb will allow you to choose how we use your personal information for communications and advertising (including opting in or out of marketing communications and targeted advertising). 
  • Opt out of interest-based advertising: You can also 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 details below. In some cases, when a third-party platform is delivering interest-based advertising to you, you may be able to adjust your account settings on the third-party platform to restrict the use of your personal information for such purposes. Please refer to the third-party platform’s privacy policy to understand your privacy choices on that platform.   
  • Unsubscribe from marketing communications: To unsubscribe from our email 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.
  • Access and correction: If you need to access or correct any information we have about you, please contact us using the details 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.

 

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.

Shine the Light Law

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 10 (“Contact information”) below.

7. 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.

8. 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.

9. Changes to This Policy

At our discretion, we may change our privacy policy to reflect changes in the law and our current practices. We will take reasonable steps to let you know about changes via our Services or by email. 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.

10. Contact Information

To exercise any of your data privacy rights, you may contact us using the information provided below:

Phone: 914-921-8800

Email: sayhello@TheScrubb.com

Postal mail:

TheScrubb
2 Landmark Square
Stamford, CT 06901
Attn: TheScrubb – Privacy Officer