Global Online Tracking Policy

A tracking technology is a mechanism allowing the website to monitor and measure user behavior and interest for multiple purposes. Some are necessary for internet operation and functioning, performance measures, load balancing or maintenance; some others provide services to the user for context and behavior-based customization, some may also be used for marketing purposes and profiling.

There are different types of online tracking technologies used on the internet as summarized below. The most common online tracking technology used today is called “Cookies”. This policy is intended to apply broadly to all types of online tracking technologies, including Cookies. All rules and practices listed in this document apply in similar ways for these other technologies even if the term “cookies” is used.

A cookie is a small data file, typically a text file of letters and numbers, that is placed by either our web sites (these are called “first party cookies”) or by other web sites that provide the content or features on the web page that you are viewing (these are called “third party cookies”). Cookies are sent by the web servers for our web sites, or by the web servers for the third-party content provided on our sites and are stored on your device. Your device can be, but not limited to, a personal computer, mobile device, personal assistant, or an Internet-connected smart TV.

Cookies enable the web site that set the cookie to store small bits of information on your device and retrieve that information at a later time. Unlike flash cookies, which we describe below, each cookie is unique to the web browser you are using on your device, so if you visit our web sites from multiple devices or multiple web browsers, our web sites will set separate cookies on each device and browser.

Other technologies that perform functions like cookies include:

• Single-pixel tags, which also are known as web beacons, web tags and clear GIFs, are graphics that function like cookies. The tags are not visible when viewing a web page or email because of their small size. They work by sending information along with the request to the web server with image.
• ETags are unique values used for web page caching that allow a web site visitor to be recognized in subsequent visits.
• Scripts are code that is embedded into some of our web pages that provide certain information about your web browser to the code provider when you visit those web pages.
• Flash cookies, also known as a local shared object, are used by the Adobe Flash Player and can contain not only the type of information stored in other cookies, but also information specific to Adobe Flash Player, such as where a video stopped playing on your device. Flash cookies are also capable of storing more information than other cookies. Flash cookies are different from other cookies in that they can share information among different web browsers on your device. We only use Flash Cookies to enhance the user experience when we deliver rich content such as video clips. Users who wish to disable these types of cookies can do so as described below.
• We do not use Fingerprinting technologies.

When you use a mobile application or device, we use data collection tools to collect information about your use of and interaction with the mobile application, such as operating system type, browser type, domain and other system settings, search queries, the time zone in which the mobile device or tablet is located, mobile phone service provider, metadata and other information associated with other files stored on your device. We may also collect information about the location of the mobile device or tablet used to access the mobile application (“Location Data”).

• Location Data includes: (i) the location of the mobile device or tablet derived from GPS or WiFi use; (ii) the IP address of the mobile device or tablet or internet service used to access the Services; and (iii) other information made available by a user or others that indicates the current or prior location of the user, such as geotag information in photographs. We will inform you if a specific mobile application collects precise Location Data.
• Advertising IDs, like Apple IDFA (Identifier for Advertisers) or GAID (Google Advertising ID) are unique, user-resettable IDs for advertising. They are a random device identifier assigned by Apple or Google to a user’s device, not us. Those identifiers can be used by mobile applications to evaluate quality of marketing campaigns.

As explained above, tracking technologies, like cookies, are used for multiple purposes ranging from strictly necessary ones used for web site operation, to others which help us improve your experience and customize content provided to you. Cookies may serve many functions. They can help remember your username and preferences, analyze how well our web sites are performing, and enable us to recommend content that we believe may be most relevant to you. Most cookies identify your device’s web browser rather than identifying you personally, however, as described further below, certain cookies can be linked to other personal information we collect from or about you.

We use both session cookies, which are temporary cookies that are erased from your device’s memory when you close your Internet browser or turn off your device, and persistent cookies, which are stored on your device until they expire, unless you delete them before that time.

Session cookies enable our web sites to remember your web site preferences during the duration of your visit until you close your web browser. For example, whether you have identified yourself as a health care professional or a resident of a particular country.

Certain types of persistent cookies enable us to tell whether your device’s Internet browser has been used to visit our web sites before as well as which pages you have visited on our web sites. If you register an account on one of our web sites, persistent cookies, which we refer to as registration cookies, enable our web sites to remember you personally when you visit our web sites in the future.

If you are signed into our web sites, we may combine information about you from registration cookies and analytics cookies to identify which pages you have visited on our web sites. In the United States, if you accept all optional cookies but leave one of our web sites without becoming a registered user, we may use cookies in conjunction with third parties to serve advertisements to your device to remind you about our web site which you had previously visited. We may also use cookies for measurement purposes.

We have grouped the cookies our web sites use into five categories to help you understand the purposes for which they are used and the options you have to control them. We describe these tracking categories and your available choices to control them below. In most countries, users to our web sites can indicate their consent to the use of configurable cookies by using the cookie preference tool where they can elect to “Customize” their choices. Where used, these tools will display prominently on a user’s first visit, whenever the cookie cache is cleared, or anytime via a prominent Cookie Panel button. By using these tools, a user can easily set and manage their cookie preferences.

In countries where the cookie preference tool has not been deployed, end users may elect to block cookies in their browser settings. Most web browsers enable users to manage preferences for cookies. If you want to block or remove cookies that are already installed on your browser per your previous permission, you can manage and delete them through your browser settings. The ‘Help’ feature on most browsers provides guidance on how to block or delete cookies. However, blocking some types of cookies may impact your experience of the site and the services we are able to offer that depend on Strictly Necessary and Functional cookies.

If you would like to opt-out of or limit the cookies set by other companies who deliver e-mail communications on our behalf or place our advertisements on other web sites, you may do so by following the options provided by:

• Network Advertising Initiative at: https://optout.networkadvertising.org/
• European Interactive Digital Advertising Alliance at: http://youronlinechoices.eu (if you are located in the EU)
• Digital Advertising Alliance (DAA)’s self-regulatory opt-out page at: https://optout.aboutads.info/ and mobile application-based “AppChoices” download page at: https://youradchoices.com/appchoices
• Some browser add-ons may also provide tracking technologies management functionalities. Consult your browser extensions to know which ones are available for your browser and how to install them.
• The Apple IDFA default setting is opt-out. Applications that want to access this ID will ask you to opt-in. IDFA can be reset manually.
• For GAID, opt-out within Google Play apps.

For mobile devices, users typically configure their tracking preferences either during initial set up of individual applications or within the application themselves post installation. If you do not want us to collect Location Data from your mobile device, please delete the mobile application or disable the location settings on your device or tablet. Note, disabling the location setting may affect your ability to access and use that mobile application.

Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the web sites you visit indicating that you do not wish to be tracked (“DNT-signal”). As reflected throughout this Policy, we are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms described in our cookie panel, where deployed. In addition, where we deploy a cookie panel, it is designed to identify a browser-initiated DNT-signal and apply it to the cookie settings per your preferences. However, despite our best efforts, this may not function for all browsers. Using the cookie banner settings will ensure that your preferences are appropriately reflected.

Despite the protections described above, whether we deploy a cookie panel or not in your market, we do not currently recognize or respond directly to browser initiated DNT signals.

We may update this Policy periodically in response to changing laws, regulations, and industry practices. We reserve the right to modify, add or remove portions of this Policy at our discretion. If we decide to change this Policy, we will post the updated version on www.msdprivacy.com. If the changes are material, we will post the changes prior to the effective date of the change.