Simulmedia
Date signed: 1/7/2025
| TPWA PIA Questions | TPWA PIA Answers |
|---|---|
| OPDIV: | CMS |
| TPWA Unique Identifier (UID): | T-6477098-220737 |
| Is this a new TPWA? | Yes |
| Please provide the reason for revision | |
| Will the use of a third-party Website or application create a new or modify an existing HHS/OPDIV System of Records Notice (SORN) under the Privacy Act? | No |
| Indicate the SORN number (or identify plans to put one in place.) |
|
| Will the use of a third-party Website or application create an information collection subject to OMB clearance under the Paperwork Reduction Act (PRA)? | No |
| Indicate the OMB approval number and approval number expiration date (or describe the plans to obtain OMB clearance.) |
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| Does the third-party Website or application contain Federal Records? | No |
| Describe the specific purpose for the OPDIV use of the third-party Website or application: | CMS will use Simulmedia to and deliver targeted TV and streaming advertising. Simulmedia does not collect Personally Identifiable Information (PII) in the course of these advertising activities and therefore, does not share PII with CMS. Simulmedia provides CMS with conversion tracking reports to all CMS to determine the effectiveness of advertising campaigns. Conversion tracking provides information about users’ activities regarding ads, including whether an ad is clicked on, or a transaction is completed. |
| Have the third-party privacy policies been reviewed to evaluate any risks and to determine whether the Website or application is appropriate for OPDIV use? | Yes |
| Describe alternative means by which the public can obtain comparable information or services if they choose not to use the third-party Website or application: | If consumers do not want to interact with advertisements from ads delivered by Simulmedia, consumers can learn about CMS campaigns through other advertising channels such as TV, radio, CMS websites, and events. |
| Does the third-party Website or application have appropriate branding to distinguish the OPDIV activities from those of nongovernmental actors? | Yes |
| How does the public navigate to the third party Website or application from the OPIDIV? | Other |
| Please describe how the public navigate to the third-party website or application: | Not Applicable. The CMS websites do not link to Simulmedia. Simulmedia is an independent platform which includes space for advertising and provides advertisers with a tool used to place and track digital advertising. |
| If the public navigate to the third-party website or application via an external hyperlink, is there an alert to notify the public that they are being directed to a nongovernmental Website? | No |
| Has the OPDIV Privacy Policy been updated to describe the use of a third-party Website or application? | Yes |
| Provide a hyperlink to the OPDIV Privacy Policy: | The above is the privacy policy for all CMS websites unless a separate one is noted below: |
| Is an OPDIV Privacy Notice posted on the third-party Website or application? | No |
| Is PII collected by the OPDIV from the third-party Website or application? | No |
| Will the third-party Website or application make PII available to the OPDIV? | No |
| Describe the PII that will be collected by the OPDIV from the third-party Website or application and/or the PII which the public could make available to the OPDIV through the use of the third-party Website or application and the intended or expected use of the PII: | Not applicable. CMS does not collect any PII through the use of Simulmedia nor will Simulmedia make available any PII to CMS. |
| Describe the type of PII from the third-party Website or application that will be shared, with whom the PII will be shared, and the purpose of the information sharing: | Not Applicable. Simulmedia does not collect or share PII. |
| If PII is shared, how are the risks of sharing PII mitigated? | Not Applicable. Simulmedia does not collect or share PII. |
| Will the PII from the third-party Website or application be maintained by the OPDIV? | No |
| Describe how PII that is used or maintained will be secured: | Not applicable |
| What other privacy risks exist and how will they be mitigated? | Cookies, pixels, web beacons, and user data segment profiles present the risk that an application could collect info about a user’s activity for purposes that the user did not intend. Simulmedia collects non-PII by placing a cookie or pixel on CMS websites and on ads sponsored by CMS on third party websites. Collected non-PII may include; plan type, IP address, browser types, operating systems, domain names, access dates and times and app interaction, referring website addresses, online transactions, browsing and search activity, device IDs and network type and service provider. A pixel allows Simulmedia to collect info regarding the use of the web page. A cookie is a small text file stored on a website visitor’s computer that allows the site to recognize the user and keep track of preferences. Simulmedia uses visitor clicks and views of ads to judge which ads will result in greater conversions. CMS ads carry persistent cookies, stored on a user’s computer for up to 180 days, that enable CMS to display ads to individuals who have previously visited CMS websites. CMS and Simulmedia provide consumers with the data that is collected and the data gathering choices included in their website privacy policies. Tealium iQ Privacy Manager keeps track of users’ preferences in reference to tracking. When a user is routed to CMS websites by clicking on a CMS ad displayed through Simulmedia, and the Tealium iQ Privacy Manager is present, users are able to control which cookies they want to accept. Tealium iQ Privacy Manager is found in the privacy policy on CMS websites. Users may also disable cookies through their web browser. CMS includes the Digital Advertising Alliance AdChoices icon on all targeted digital advertising. Simulmedia agrees to delete all cookies and any data associated with these cookies upon request by CMS. CMS will conduct periodic reviews of Simulmedia privacy policy. |
Third-Party Web and Application (TPWA) Privacy Impact Assessment (PIA) published by CMS as an Operating Division of the U.S. Department of Health and Human Services