Last Updated: August 2025
Real World Data, a division of Publicis Health, LLC (“we,” “us,” or “our”), a next-generation insights and advisory business that combines data, design, and dialogues to deliver activatable insights and transformational intelligence to healthcare marketers. This Privacy Notice sets out how we collect, use, share, and protect any information we collect in connection with your use of our AI-powered agent, PISTACHIO. This Privacy Notice also explains the measures we take to safeguard your information and describes how you may contact us regarding our privacy practices.
Please read this Privacy Notice thoroughly. If you do not want us to collect, use or disclose your Personal Information in the ways described in this policy, please do not use PISTACHIO. By using PISTACHIO, you acknowledge that you understand that we may use your Personal Information in the ways described in this Notice.
Some portions of this Privacy Notice apply only to Clients and/or Consumers of particular regions, countries, or U.S. states. In those instances, we have indicated that such language applies only to certain Clients and/or Consumers.
This section of our Privacy Notice lists the categories of Personal Information we collect from you when you access PISTACHIO and explains how we process that Personal Information.
We collect the following categories of Personal Information from you when we provision an account for you in PISTACHIO and provide access:
The following table provides information about our purposes and legal bases for collecting, processing, and disclosing the categories of Personal Information listed in “Information We Collect.”
| Purpose | Description | Legal Basis |
|---|---|---|
| Administer and Manage Access to PISTACHIO | Includes creating a PISTACHIO user account; | Performance of Contract Legitimate Interests, including to manage our business operations and communicate with Clients and Consumers Legal Obligations |
| Responding to Data Subject Requests | Responding to your requests when you contact us through the data access request form to exercise your rights. | Legal Obligations |
| Legal & Compliance | Complying with applicable laws; complying with legal processes; responding to requests from public and government authorities; meeting national security or law enforcement requirements; enforcing our terms and conditions; protecting our operations; protecting the rights, privacy, safety, and property of Real World Data employees, clients, consumers, and other relevant individuals; and pursuing available legal remedies, when appropriate. | Legal Obligations Legitimate Interests, including to comply with applicable law and protect Real World Data interests |
| Corporate Transactions | In the event of a corporate transaction including, for example, a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction. | Legitimate Interest Performance of a contact to support our corporate transactions |
| Emergency, Incident Response, & Security | Actively monitoring use of the PISTACHIO tool to ensure adequate incident prevention, response, and documentation; requesting assistance from emergency services; and sending notifications and alerts in the event of emergencies. | Performance of Contract Legitimate Interests, including to comply with applicable law, protect Verilogue interests, and protect our Clients and Consumers Legal Obligations |
| Other Internal Purposes | Other internal purposes, such as: internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control and legal compliance. | Legitimate interests, including to support our internal operations and conduct research |
We do not process your Personal Information in any way that involves automated decision-making.
We do not sell or share your Personal Information.
We retain your Personal Information for as long as needed to provide you with access to PISTACHIO. Once you are deleted from our system as a user, we delete any Personal Information that we have collected from or about you.
We would otherwise only retain the data for longer than the timeframe that access is provided to PISTACHIO where:
We do not disclose your Personal Information to service providers or third parties.
Personal Information we collect from and about you may be transferred outside of your country of residence, including to the U.S. and other countries that may not provide the same level of data protection as your country of residence. Nonetheless, Real World Data will process your Personal Information in accordance with this Privacy Notice and applicable privacy laws.
To obtain additional information regarding and/or a copy of the safeguards Verilogue has implemented to facilitate cross-border transfers of Personal Information, please contact us at privacyofficer@publicisgroupe.com.
Please use this LINK if you want to make use of any of your below mentioned legal rights.
Subject to certain exceptions and the jurisdiction in which you live, if you are a resident of the EU, the GDPR provides you with specific rights regarding your Personal Data. This subsection describes your rights and explains how to exercise those rights regarding Personal Data that we hold about you. These rights include:
You can access all Personal Data we hold about you, know the origin of this Personal Data and obtain a copy in an understandable format. You may also use your right to access your Personal Data to control the exactness of the data and have them rectified or deleted. You have no justification to provide to exercise your right to access;
In order to avoid that inaccurate or incomplete Personal Data relating to you is process or shared, you can ask us to rectify them;
You may request the erasure or deletion of the Personal Data we hold on you. This is not an absolute right since we may have to keep your Personal Data for legal or legitimate reasons. You may, for example, exercise your right to deletion in the following cases:
(a) if you have withdrawn your consent to the processing (see below);
(b) if you legitimately objected to the processing of your data (see below);
(c) when data is not or is no longer necessary for the purposes for which it was initially collected or processed;
(d) the data is processed unlawfully (e.g., publishing hacked data);
We process your Personal Data based on our legitimate interest (to determine to which processing this applies, please refer to Section II of this Privacy Notice), you may at any time object to the processing of your Personal Data for reasons relating to your personal situation. We may nevertheless, on a case-by-case basis, reject such a request by pointing out the legitimate and imperious reasons justifying the processing of this data which prevail on your interests, rights and freedoms, or when this data is necessary to establish, exercise or defend a right before a Court.
The right to limit the processing completes your other rights. This right means that the data processing relating to you and that we are performing is limited, so that we may keep this data, but we cannot use it or process it in any other manner. This right applies in specific circumstances, i.e.:
(a) if you challenge the exactness of your Personal Data. The processing is then limited for a period of time so that the agency may verify the exactness of the Personal Data;
(b) if the processing is unlawful and you object to the erasure of your Personal Data and request instead that its use be limited;
(c) if we do not need the Personal Data for the purposes mentioned above in Section I anymore, but you still need it to establish, exercise or defend rights before a Court; and
(d) in the cases where you objected to the processing which is based on the legitimate interests of the agency, you may ask to limit the processing for the time necessary for us to verify if we can accept your objection request (i.e., the time necessary to verify whether the legitimate reasons of the agency prevail over yours).
You may unsubscribe or object, at any time and without any justification, to the reception of direct marketing communications. Simply either (i) click on the link in the footer of the communications you receive from us; or (ii) use the hyperlink above; or (iii) send us an email at the email address set out in the “Further Information” section below with the word unsubscribe in the subject field of the email.
(a) You may request to retrieve the Personal Data you provided us with, in a structured, commonly used, and machine-readable format, for personal use or to share them with a third party of your choice.
(b) This right only applies to Personal Data you provided us with, directly or indirectly, and which was processed through automated means, if this processing is based on your consent or the performance of a contract. Please check the list of our Personal Data processing activities’ legal grounds (in Section II of this Privacy Notice) to know whether our processing is based on the performance of a contract or on consent.
(a) You may read Section II of this Privacy Notice in order to identify the purposes for which the processing of your Personal Data is based on your consent.
(b) If you are unsatisfied with the way we process your Personal Data or if your request has been rejected, you may also lodge a formal complaint with your local competent data protection authority.
(c) Personal Data will be stored in accordance with our applicable data retention requirements and corporate policies. The retention period for Personal Data varies depending on the type of Personal Data and the purposes of processing it.
(d) We will respond without undue delay and in any event within one month from the data we receive your request. This timeframe can be extended by two months to take the complexity of the request, or the number of requests received into account. In this case, we will inform you within one month from receiving your request, specifying the reasons for extending the response timeframe.
Residents of certain US states, such as California, Virginia, Colorado, Connecticut, and Utah, have specific rights regarding their Personal Data. This section describes how to exercise those rights and our process for handling those requests. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)
You may request access to your Personal Data that we collect, use, disclose, or sell. In particular, you may request:
When exercising the right to access Personal Data, you have the right to obtain materials in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. When we receive and verify your request to access your Personal Data, we will make best efforts to fulfill your request unless an exception applies. We will not disclose your government identification numbers, financial account numbers, health insurance or medical identification numbers, account passwords, security questions and answer, or unique biometric data; however, to the extent we have this information, we will inform you that we have collected this information. You are permitted 2 access reports every 12 months.
You may also request that we delete any Personal Data that we obtained about you. However, we may retain Personal Data for certain important purposes, as set out by applicable law.
When we receive and verify your request to delete your Personal Data, we will proceed to delete the data unless an exception applies. We will retain a record of your deletion request in order to keep your Personal Data deleted, unless and until you provide consent for the processing of your Personal Data post your deletion request.
If you believe we hold inaccurate personal information about you, you may request that we correct that information. We may ask for documentation showing that the information you submit is accurate and the Personal Data we hold is inaccurate. Once we receive your request, we will verify your identity and taking into account the type of personal information and the purposes of our holding that personal information we will make best efforts to complete your request. We may deny your request if we determine that the contested Personal Data is more likely than not accurate. Additionally, we may choose to delete your Personal Data in response to your request to correct your Personal Data if the deletion of your Personal Data would not negatively impact you.
You may request that we limit the use and disclosure of your Sensitive Personal Data. However, we may deny your request in part of in full under uses authorized by applicable law.
We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise your privacy rights.
We do not sell any Personal Data as the term ‘sell’ is used in US state privacy laws like the California Consumer Privacy Act and the Virginia Consumer Data Protection Act.
We do not process or share Personal Data for cross-contextual behavioral advertising or targeted advertising.
We do not use automated decision-making, including profiling, to make decisions that have legal or similarly significant effects with respect to Clients or Consumers.
Residents of Canada have the following rights regarding our collection and use of their Personal Information.
You have a right to access your Personal Data in our control. We will also provide you with a description of what uses we have made of your Personal Data and which third parties we have shared it with. In some cases, we may not be able to provide you with access to your Personal Data, such as where:
If you note any inaccuracies or wish to update any of your Personal Data, we will make those changes upon your request.
At any time, you may withdraw your consent for us to process your Personal Data for the purposes described at Section II of this Privacy Notice. However, this may affect our ability to offer you some of the services. For example, we may not be able to respond to your queries.
To exercise your data subject rights, you can submit your request here, by sending an email to or by contacting us at 1-833-983-0087 .
For security purposes (and as required under US state laws), we will verify your identity—in part by requesting certain information from you—when you make a request to access, correct, or delete, your Personal Information. The verification process will utilize an email verification process, a telephone number verification process, and, if applicable, a request for any assigned ID number previously communicated to you. If we are unable to complete your request fully for any reason, we will provide you additional information about the reasons why we could not comply with your request.
Authorized agents may also submit requests via the methods described above, where permitted by applicable privacy laws. We will take steps both to verify your identity and to verify that your agent has been authorized to make a request on your behalf by requesting your agent to provide us with a signed written authorization or a copy of a power of attorney executed by you.
Further, to opt out of receiving marketing-related emails, you can use the unsubscribe link at the bottom of any of our email communications, or submit a request via the above methods.
We will not discriminate against you for exercising your data subject rights. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.
It is your right to appeal a decision made on your data subject requests. You may appeal this decision within 60 days of receiving your response from us. To submit your appeal contact privacyofficer@publicisgroupe.com or visit our [portal]. We will respond to your appeal in accordance with applicable law.
We do not provide financial incentives to consumers who allow us to collect, retain, sell, or share their Personal Information. We will describe such programs to you if and when we offer them to you.
We sell “Covered Information” as defined under Nevada law, but we generally do not disclose or share “Personal Information” as defined under Nevada law for commercial purposes. Under Nevada law, you have the right to direct us to not sell your Covered Information to third parties, as defined under Nevada law. Sale is defined under Nevada law as “the exchange of covered information for monetary consideration by the operator to a person for the person to license or sell the covered information to additional persons.” To exercise this right, if applicable, you or your authorized representative may contact our Privacy Office at privacyofficer@publicisgroupe.com.
You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at [Email] with the word unsubscribe in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about transactions, servicing, or our ongoing business relations.
We do not collect the Personal Information of minors under 16 years of age.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit https://www.allaboutdnt.com
We use a variety of methods, such as firewalls, intrusion detection software and manual security procedures, designed to secure your data against loss or damage and to help protect the accuracy and security of information and to prevent unauthorized access or improper use. If you have questions about how we secure your data, please contact [Email].
We may update this Privacy Notice from time to time. When we do so, we will make the updated notice available on this page. Real World Data encourages you to review this page regularly for any changes.
To contact our Data Protection Officer responsible for your country or region, please email us at privacyofficer@publicisgroupe.com.
If you consider that we are not complying with this Privacy Notice, if you have any questions in relation to this Privacy Notice, or have questions about your rights and choices, please contact privacyofficer@publicisgroupe.com. In your email, please indicate your country of residence. Data subjects in Europe may also lodge a formal complaint with their competent data protection authority.
This Privacy Notice has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at privacyofficer@publicisgroupe.com.