Supplemental California Consumer Privacy Act Notice at Collection and Privacy Policy

Last updated April 1, 2026

This Supplemental California Consumer Privacy Act Notice at Collection and Privacy Policy apply to California residents only. In this document, we, PeerDirect Publishing, provide:

A Notice at Collection regarding the personal information of California residents that we collect about users of the websites, and online newsletters that we operate (our “Services”); and
A California Consumer Privacy Act Privacy Policy setting forth information about how we handled the personal information of California residents over the last 12 months and rights that California residents may have under the California Consumer Privacy Act of 2018, amended from time to time, including by the California Privacy Rights Act of 2020 and its implementing regulations. (“CCPA”)

This document does not reflect our processing of California residents' personal information where an exception under the CCPA applies.

1. Notice at Collection Online.

If you applied or are applying for a job with us, please see the P\S\L Group Employment Candidate Privacy Statement for a description of the categoeies of personal information that we collect from and about you, the purposes for which we use and disclose it, and information about how long retain it. If we hire you, we separately provide you with an Employee CCPA Notice at Collection.

We do not use sensitive personal information to infer characteristics about users of our Services, and would only use sensitive personal information of users of our Services for purposes referred to under Subsection 1798.121(a) of the CCPA. We will delete, erase or anonymize the personal information of users of our Services within one month after their personal information is no longer necessary for us to provide them with any information or services they have requested, fulfill the purposes for which we collected the personal information as described in our privacy notices, comply with any legal obligations to which we are subject, or defend any legal claim against us or support any legal claim made by us, including any potential appeal. Please find our CCPA Privacy Policy directly below.

2. CCPA Privacy Policy

A. Our Personal Information handling Practices over the Preceding 12 Months

The table below sets out the categories of “personal information” and “sensitive personal information” (as defined by the CCPA) about California residents that we collected, the sources of such information, and whether we disclosed such personal information and to whom if so, over the preceding 12 months. In the descriptions of categoes of personal information below, “consumer” means “California resident”. We used the personal information for the purposes set forth in the CCPA Notices at Collection that we provided to you. We did not “sell” or “share” California residents' personal information, as there terms are defined in the CCPA. We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.

Category of personal information	Did we collect? If so, from what source?	Did we disclose? If so, to whom and for what purpose?
Categories of “personal information” as defined by the CCPA
Identifiers such as real name, alias, postal address, unique personal identifer, Internet Protocol (IP) address, email address, account name, driver's license number, or other similar identifiers.	Yes, from users of our Services, their device, their network provider, sponsors of medical education activities, sponsors of market research surveys, national or local registries of physicians, national or local medical associations, the public websites of hospitals, medical offices, clinics and educational institutions, academic journals, and professional social networking platforms including LinkedIn.	Yes: We may disclose personal information to affiliated and non-affiliated service providers to help us fulfill the purposes set forth in this Privacy Policy; If you respond to a market research survey and we have your consent, we may disclose an identifier that relates to you and your survey responses to the sponsor of the survey. We may disclose your personal information to government entities as required by applicable law or necessary to protect against harm.
Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, or any other financial information, or, but excluding publicly available information that is lawfully made available to the general public from federal, state, or local government records.	Same as above	Same as above
Characteristics of protected classifications under California or federal law, including age, race, national origin, citizenship, marital status, sex (including gender, gender identify, gender expression), military or veteran status, nationality, ancestry or ethnicity.	No.	N/A
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes, directly from users of our Services.	Yes: We may disclose personal information to affiliated and non-affiliated service providers to help us fulfill the purposes set forth in this Privacy Policy; If you respond to a market research survey and we have your consent, we may disclose an identifier that relates to you and your survey responses to the sponsor of the survey. We may disclose your personal information to government entities as required by applicable law or necessary to protect against harm.
Biometric information.	No.	N/A
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement.	Yes, directly from users of our Services, their device and their network provider.	Yes: We may disclose personal information to affiliated and non-affiliated service providers to help us fulfill the purposes set forth in this Privacy Policy; If you respond to a market research survey and we have your consent, we may disclose an identifier that relates to you and your survey responses to the sponsor of the survey. We may disclose your personal information to government entities as required by applicable law or necessary to protect against harm.
Geolocation data.	Yes, from users of our Services, their device, their network provider, sponsors of medical education activities, sponsors of market research surveys, national or local registries of physicians, national or local medical associations, the public websites of hospitals, medical offices, clinics and educational institutions, academic journals, and professional social networking platforms including LinkedIn.	Same as above.
Audio, electronic, visual, or similar information.	Yes, from users of our Services, their device, their network provider, sponsors of medical education activities, sponsors of market research surveys, national or local registries of physicians, national or local medical associations, the public websites of hospitals, medical offices, clinics and educational institutions, academic journals, and professional social networking platforms including LinkedIn.	Same as above.
Professional or employment-related information.	Yes, from users of our Services, their device, their network provider, sponsors of medical education activities, sponsors of market research surveys, national or local registries of physicians, national or local medical associations, the public websites of hospitals, medical offices, clinics and educational institutions, academic journals, and professional social networking platforms including LinkedIn.	Same as above.
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g; 34 C.F.R. Part 99).	Yes, from users of our Services, their device, their network provider, sponsors of medical education activities, sponsors of market research surveys, national or local registries of physicians, national or local medical associations, the public websites of hospitals, medical offices, clinics and educational institutions, academic journals, and professional social networking platforms including LinkedIn.	Same as above.
Inferences drawn from any of the personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes, we draw inferences about California residents' preferences and characteristics based on the information we have about them.	Same as above.
Categories of “sensitive personal information” as defined in the CCPA
A consumer's social security, driver's license, state identification card, or passport number.	No.	N/A
A consumer's account log-in, financial account, debit card, or credit card number in combination with any required security or access codes, passwords, or credentials allowing access to an account.	Yes, from users of our Services.	Yes, we may disclose personal information to affiliated and non-affiliated service providers to help us fulfill the purposes set forth in this Privacy Policy.
A consumer's precise geolocation.	No.	N/A
A consumer's racial or ethnic origin, citizenship, or immigration status, religious or philosophical beliefs, or union membership.	No.	N/A
The contents of a consumer's mail, email, and text messages, unless the business is the intended recipient of the communication.	No.	N/A
A consumer's genetic data.	No.	N/A
The processing of biometric information for the purpose of uniquely identifying a consumer.	No.	N/A
Personal information collected and analyzed concerning a consumer's health.	No.	N/A
Personal information collected and analyzed concerning a consumer's sex life or sexual orientation.	No.	N/A

B. CCPA Rights

As a California resident, you have the following rights under the CCPA, subject to the limitations and exceptions within the CCPA:

The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
The right to delete personal information that we have collected from you.
The right to correct inaccurate personal information that we maintain about you.
The right to opt-out of the sale or sharing of your personal information by us. We do not sell, or share for cross-context behavioral advertising, any of the categories of personal information that we collect about California residents
The right to limit our use and disclosure of sensitive personal information to purposes specified in Cal. Civ. Code § 1798.121(a). We do not use or disclose sensitive personal information for purposes other than those specified in Cal. Civ. Code § 1798.121(a).
The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, in violation of California Civil Code § 1798.125.

C. How to Exercise CCPA Rights

To submit a request to exercise your rights to know, delete or correct, please submit an email request to privacy@peerdirect.com and clearly specify the nature of your request, including the information about you that you would like to know, the personal information about you that you would like to have deleted, or the personal information about you that you would like to have corrected.

Only you, or someone legally authorized to act on your behalf, may make such a request related to your personal information. You may designate an authorized agent by taking the steps outlined under “Authorized Agent” further below. We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once we have verified your identity, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why. If you do not provide enough information for us to reasonably verify your identity, we will not be able to fulfill your request. We will only use the personal information you provide to us in a request for the purposes of verifying your identity and to fulfill your request. If we deny your request, we will explain why.

D. Authorized Agent

You can designate an authorized agent to make a request under the CCPA on your behalf if the authorized agent is a natural person or a business entity registered with the Secretary of State of California, we receive a written authorizatino stating that you have authorized the authorized agent to submit a request on your behalf which has been signed by you and the authorized agent, and we have verified the identity of you and the authorized agent.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

3. Updates and Changes

We may change our Notice at Collection and Privacy Policy from time to time. If we make a material change to how we collect, use, or disclose personal information, we will prominently post an updated Notice at Collection and CCPA Privacy Policy on our Services and update the “Last update” date above, and may take other steps to bring the changes to your attention or seek your consent to the changes. If you disagree with these changes, you may discontinue using the Services.