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Ad Implementation PolicyEffective Date: 28th November 2025

1. Introduction

This Ad Implementation Policy (the “Policy”) sets forth the binding rules, standards, and obligations governing the technical integration, deployment, and operational management of advertisements and Spark context-triggered messages (“Ads”) within Publisher Properties.“Publisher Properties” include, without limitation, mobile applications, websites, electronic health record (“EHR”) systems, health system environments, and other digital platforms operated or controlled by the Publisher.

As part of the Doceree Spark program (the “Program”), Doceree delivers Ads and real-time, clinically triggered Spark Messages through the Doceree Spark Platform (“Spark Platform”). The Spark Platform is Doceree’s AI-powered, patient-led and clinical-context–aware communication framework that enables three distinct messaging pathways, Co-Pay Spark, Trial Spark, and Drug Spark, to reach healthcare professionals (“HCPs”) at relevant points within their workflow. These capabilities support health systems and EHR partners by enhancing patient engagement, improving access to therapies, and enabling more informed decision-making at the point of care.

This Policy supplements, and must be read in conjunction with, Doceree’s Ad Placement Policy , which forms an integral part of the obligations of all Publishers participating in the Program. By participating in the Program, Publishers acknowledge and agree that Spark Ads and Messages must be implemented in a clinically safe, non-disruptive, and compliant manner consistent with the Publisher’s environment and applicable legal, regulatory, and workflow requirements.

Publishers are solely responsible for ensuring that Ads and Spark Messages are properly implemented in accordance with this Policy, the Ad Placement Policy, all applicable laws, and all contractual obligations under the Program. Failure to do so may result in immediate remedial action by Doceree, including suspension or termination of Program access, removal of Ads, withholding of payments, and the pursuit of any legal or equitable remedies available.

For the avoidance of doubt, this Policy applies to all current and future integrations of Ads and Spark Messages within Publisher Properties, whether delivered through Doceree code, EHR-embedded solutions, API-based integrations, third-party SDKs, or any other approved technology used as part of the Program. Compliance with this Policy, including all technical, operational, and content-related provisions, is a material condition of participation in the Program.

2. Ad Placement Standards

  • Non-Disruptive User Experience
    Publishers must ensure that all Ads and Spark context-triggered messages (“Spark Messages”) deployed through the Program are implemented in a manner that is non-disruptive, clinically appropriate, and consistent with the ordinary and intended use of the Publisher Property. Within EHR and health system environments, Spark Messages must never interfere with clinical workflows, including but not limited to medication ordering, diagnosis entry, clinical documentation, prescribing actions, or patient-chart navigation.

    Spark Messages must not overlay, obscure, or modify any core clinical or functional elements of the Publisher Property. Placement near interactive controls, such as buttons, form fields, treatment selectors, or scrollable regions, must be avoided to prevent accidental engagement.
  • Prohibition on Dead-End Screens
    Ads and Spark Messages must not be placed on screens from which users cannot navigate away without interacting with the Ad or Message. This restriction applies especially to EHR modules and health system tools where clinical tasks must remain uninterrupted. Users must be able to exit or continue their intended workflow without being forced to engage with a Spark Message. Forced interaction, blocking behavior, or gating clinical actions behind an Ad is strictly prohibited.
  • Background and External Placement Restrictions
    Ads and Spark Messages may only appear within the active and contextually approved areas of the Publisher Property. They must not appear in device-level widgets, pre-launch overlays, post-visit screens, patient-facing surfaces, or in any external frames detached from the Publisher Property.

    Spark Messages may only be presented in Doceree-approved placements within EHR or health system workflows to ensure accuracy, transparency, and user trust. Under no circumstances may Spark Messages be displayed in a manner that misattributes the message origin or implies endorsement by the EHR or health system unless explicitly authorized.
  • Core Content Protection
    Publishers must ensure that Ads and Spark Messages do not obscure, replace, or interfere with any core content, functional components, or clinical modules of the Publisher Property. Within EHR and health system environments, Spark Messages are strictly prohibited from appearing in or near critical clinical surfaces, including patient identification headers, medication selection and ordering interfaces, diagnosis and problem-list entry fields, lab results display, clinical documentation areas, clinical decision support (CDS) alerts, and chart review screens. Interruptive ad formats, such as pop-ups, interstitials, expandable units, floating overlays, or rewarded formats, are not permitted under any circumstances in Spark-integrated workflows, as they may compromise patient safety, disrupt clinical tasks, or impede workflow continuity.
  • Non-Content-Based Screens
    Ads and Spark Messages must not be displayed on screens that lack substantive clinical or informational value or do not support meaningful user interactions. In EHR and health system settings, Spark Messages are strictly prohibited from appearing on thank-you pages, success confirmations, error screens, login or logout pages, idle screens, or system-level utility pages, as well as patient check-in or registration screens, consent screens, privacy or compliance notifications, medication safety warnings, and system administration panels. Displaying Spark Messages on such surfaces risks misinterpretation, diminishes message integrity, and undermines clinical trust standards essential to responsible use of Spark within care delivery environments.

3. Third-Party Content Restrictions

  • Framing and Embedding of External Content
    Publishers must not frame or embed third-party content for monetization through the Program without prior written consent from the content owner. This requirement is especially critical in EHR and health system environments, where Spark Messages must appear only alongside approved clinical or informational content to maintain clinical trust and data integrity. Content already monetized through Ads or Spark Messages must not include duplicate or conflicting integration code.
  • Integrity of Spark Message Context
    Spark Messages rely on precise, patient-led, clinical-context triggers. Publishers may not embed Spark Messages within third-party frames, widgets, containers, or modules that alter, mask, or distort the context in which Spark Messages are delivered. Any form of content layering, masking, or UI manipulation that could misrepresent the origin or trigger of a Spark Message is strictly prohibited.
  • Sub-Syndication and Inventory Reselling Restrictions
    Publishers may not permit third-party intermediaries, reseller networks, or affiliate entities to place Doceree Ads or Spark Messages. No Spark inventory may be resold, re-routed, or exposed to external demand sources, exchanges, mediation layers, or other programmatic networks. All Spark Message delivery must occur exclusively through Doceree’s direct integration to preserve accuracy, workflow safety, and compliance.
  • Distribution Channel Responsibility
    Publishers are fully responsible for ensuring that all distribution channels connected to their Publisher Property, including EHR integrations, health system deployments, mobile app stores, partner platforms, and white-labeled environments, comply with this Policy. Publishers must ensure that Spark Messages are never displayed via unauthorized intermediaries or in any environment where contextual triggers or clinical safeguards cannot be maintained.

4. Data and Information Management

  • Reporting Console and Analytics Access
    Publishers must not share access to Doceree’s reporting console, Spark analytics dashboards, or any performance or trigger-level reporting interfaces with third parties, except where Doceree has provided prior written approval specifying which data or metrics may be shared. Spark reporting may include sensitive workflow-level insights or non-identifiable clinical-context data; therefore, any unauthorized access, export, or dissemination constitutes a material breach of this Policy.
  • Protection of Spark Trigger Logic and Context Data
    Publishers must maintain strict confidentiality around all Spark trigger logic, workflow signals, and integration parameters shared by Doceree. Publishers may not disclose, replicate, infer, or attempt to reverse-engineer clinical-context signals or trigger conditions used by the Spark Platform. Any attempt to modify, intercept, store, or reuse Spark context data outside the permitted integration scope is strictly prohibited
  • Source Code SDK, and API Restrictions
    Publishers are prohibited from sharing Doceree’s source code, SDKs, APIs, integration libraries, or uncompiled code with any third party. Reverse engineering, modification, or derivative creation of Doceree’s code, Spark libraries, or integration assets are prohibited unless expressly authorized in writing by Doceree. Publishers must ensure Spark code is stored securely and accessed only by authorized technical personnel.
  • Data Handling and Security Requirements
    All data exchanged between Publisher systems and the Spark Platform, including clinical-context triggers, workflow events, and anonymized signals, must be handled securely and in accordance with applicable laws, including HIPAA, GDPR, and relevant data protection regulations. Publishers must not cache, log, or store Spark context data in any manner that could re-identify a patient or reveal clinical workflow patterns beyond the permitted scope. Secure transmission (TLS 1.2+), access controls, and audit logs must be maintained for all Spark-related technical interactions.

5. Contextual and Workflow-Based Messaging

The Spark Platform does not use behavioral tracking, interest-based profiling, or device-level identifiers to deliver Ads or Spark Messages. Instead, Spark relies solely on anonymized, real-time clinical-context signals and workflow triggers generated within compliant Publisher Properties such as EHRs and health system environments. Publishers are responsible for:

  • Ensuring that all contextual signals and workflow data used in connection with Spark are anonymized, de-identified, and compliant with applicable laws including HIPAA, HITECH, GDPR, CCPA, and relevant local privacy regulations.
  • Reviewing and updating their privacy policies to accurately describe the use of contextual, non-identifiable data for the delivery of Spark Messages, and to clarify that Spark does not employ behavioral or interest-based targeting.
  • Obtaining all legally required consents or permissions from users, health systems, or clinicians when any form of contextual data is processed or transmitted for the purpose of delivering Spark Messages, especially where jurisdictional consent requirements apply.
  • Ensuring that no patient-identifiable information, PHI, or workflow data that could enable patient re-identification is transmitted to Doceree or used to trigger Spark Messages.
  • The Spark Platform does not require, receive, process, store, or have access to Protected Health Information (“PHI”) as defined under the Health Insurance Portability and Accountability Act (“HIPAA”). Publishers must ensure that no PHI, patient-identifiable data, or any data that could reasonably be used to re-identify a patient is transmitted to Doceree or used in connection with Spark Messages or contextual triggers. Any clinical-context signals provided to the Spark Platform must be properly anonymized or de-identified in accordance with applicable law. Publishers are solely responsible for maintaining HIPAA compliance within their environments and for preventing any inadvertent disclosure of PHI to Doceree.

6. Technical Requirements and Best Practices

  • Load Performance and Workflow Safety
    Spark Messages must be loaded efficiently and reliably without disrupting or slowing down clinical workflows within EHR or health system environments. Publishers must ensure that Spark integrations do not negatively impact system performance, page load times, clinical module responsiveness, or patient-chart navigation. Robust error handling must be in place for failed Spark Message loads, and fallback mechanisms must ensure that core clinical functionality is preserved at all times
  • Trigger Frequency, Timing, and Message Appropriateness
    Spark Messages must follow Doceree’s approved clinical-context trigger logic and must not be artificially refreshed, replicated, or triggered outside of the intended workflow. Publishers may not use interstitials, pop-ups, rewarded units, or any interruptive ad formats as these are strictly prohibited in Spark implementations. Spark Messages must appear only when the validated clinical-context signal is present and must not be displayed in ways that create interruption, distraction, or excessive visibility to the user.
  • Accessibility and Usability Standards
    All Spark Messages must be accessible to users with disabilities, including compliance with applicable accessibility standards such as WCAG. Spark Message placements must support screen readers, keyboard navigation, high-contrast display modes, and closed captioning for any multimedia content. Usability must remain consistent across workflows to ensure equitable access for healthcare professionals.
  • Device, System, and Environment Compatibility
    Spark Messages must be rendered consistently across supported devices, operating systems, browser environments, and EHR interfaces. Publishers must conduct appropriate testing during integration and ongoing system updates to ensure Spark placements remain visually clear, technically consistent, and fully functional within their clinical environments. Compatibility must be validated for desktop, tablet, and specialized clinical devices used within hospitals and health systems.
  • No Clinical Influence or Medical Decision Support
    Spark Messages are informational and promotional in nature and are not intended to serve as, nor should they be interpreted as, clinical guidance, medical advice, clinical decision support, or recommendations for diagnosis or treatment. Spark Messages must not be displayed, formatted, or positioned in a manner that could suggest they influence, modify, or direct clinical judgment. All clinical decisions remain solely the responsibility of the healthcare professional, and the Spark Platform must not be used to shape, alter, or interfere with clinical care pathways, treatment selection, prescribing behavior, or patient management.

7. Compliance and Enforcement

Publishers are solely responsible for ensuring full compliance with this Policy, the Ad Placement Policy, all Spark integration requirements, and all applicable laws and regulations, including those governing data privacy, clinical workflow safety, and the handling of anonymized or de-identified clinical-context signals. Doceree may review, inspect, or audit Publisher Properties at any time, particularly EHR and health system integrations, to verify adherence to Spark placement standards, trigger integrity, technical specifications, and workflow-safety requirements. Non-compliance may result in immediate suspension or termination from the Program, removal or disabling of Spark Messages, withholding or forfeiture of payments, and the pursuit of any additional legal or equitable remedies available to Doceree.

Publishers agree to indemnify, defend, and hold harmless Doceree, its affiliates, officers, directors, employees, and clients from any claims, damages, losses, liabilities, or regulatory actions arising out of or relating to improper implementation of Ads or Spark Messages, including but not limited to workflow disruptions, misplacement of Spark Messages in clinical modules, unauthorized disclosure or misuse of contextual signals, violations of privacy or data-protection obligations, or failures to comply with applicable laws, clinical standards, or integration requirements.

8. Disclaimer

All Ads, Spark Messages, contextual triggers, content, tracking, analytics, technical tools, and related services provided through the Spark Platform or delivered within Publisher Properties are provided strictly on an “as is” basis, without any representation, warranty, or assurance of any kind, whether express or implied. This includes, without limitation, any warranties of accuracy, completeness, performance, merchantability, fitness for a particular purpose, non-infringement, or compliance with applicable laws or clinical standards. Doceree does not warrant or guarantee the timing, relevance, accuracy, delivery, or performance of Spark Messages, contextual triggers, or any outcomes associated with their use within EHR, health system, or other clinical workflows.

Doceree expressly disclaims all liability arising from the placement, display, integration, triggering, performance, or operational outcomes of Ads or Spark Messages on Publisher Properties, including any effects on workflow, user experience, or clinical decision-making. Publishers remain solely responsible for implementing Ads and Spark Messages in accordance with this Ad Implementation Policy, the Ad Placement Policy, all applicable laws, and all integration requirements governing clinical workflow safety and contextual relevance.

9. Suspension, Termination, and Remedies

Doceree reserves the right, at its sole discretion, to suspend or terminate a Publisher’s participation in the Program, in whole or in part, for any violation of this Policy, the Ad Placement Policy, or any Spark Platform integration requirements. Suspension or termination may include, without limitation, the immediate withholding or forfeiture of accrued payments, disabling of Spark Messages, or revocation of access to Spark Platform tools, reporting dashboards, or integration assets. Doceree may additionally pursue all legal or equitable remedies available, including claims for damages arising from non-compliance, improper placement of Spark Messages, interference with clinical workflows, misuse of contextual triggers, or unauthorized handling of Spark-integrated data.

For minor or remediable violations, Doceree may, at its discretion, offer a limited cure period during which the Publisher must fully correct the non-compliance. Failure to remedy within the designated timeframe may result in further enforcement measures, including permanent termination of participation in the Program and removal of all Spark Platform access.

10. Reporting Violations

Publishers must promptly report any observed or suspected violations of this Policy, including but not limited to improper display of Ads or Spark Messages, exposure of Spark Messages within prohibited clinical modules, manipulation of contextual triggers, unauthorized data handling, technical misuse of the Spark Platform, or the presentation of Ads alongside prohibited, offensive, or clinically inappropriate content. Publishers must also report any issues that may affect clinical workflow safety, including performance degradation or unexpected Spark Message behavior within EHR or health system environments.

Doceree reserves the right to conduct periodic audits of Publisher Properties, including EHR integrations, health system deployments, mobile environments, and web properties, to verify compliance, review placement behavior, and identify actual or potential violations. Publishers must cooperate fully with any audit or investigation initiated by Doceree.

11. Intellectual Property Ownership

All intellectual property rights in Ads, Spark Messages, contextual triggers, clinical-workflow logic, and all related creative assets, including, without limitation, logos, trademarks, text, images, videos, interactive elements, and any Spark Platform integration materials, remain the exclusive property of Doceree or its clients. Publishers are granted only a limited, non-transferable, non-sublicensable, revocable license to display Ads and Spark Messages solely in accordance with this Policy, the Ad Placement Policy, and all Spark Platform integration requirements.

Publishers shall not modify, reproduce, distribute, create derivative works of, reverse engineer, or otherwise exploit any Ads, Spark Messages, contextual triggers, Spark integration assets, or any component of the Spark Platform without Doceree’s prior written consent. Unauthorized use, replication, or alteration of Ads or Spark Platform materials, including trigger logic, SDKs, APIs, code snippets, or message configurations, constitutes a violation of this Policy and may result in immediate suspension, termination, or legal action.

This Section applies in addition to, and does not limit, any other intellectual property rights held by Doceree or its clients under applicable law, including those governing digital content, clinical-workflow tools, integration software, and proprietary communication frameworks used within EHR or health system environments.

12. Audit and Access

Doceree or its authorized agents may, at any time and at Doceree’s sole discretion, conduct audits, inspections, technical reviews, or workflow assessments of Publisher Properties, including EHR instances, health system environments, mobile and web applications, to verify compliance with this Policy, the Ad Placement Policy , and all Spark Platform integration and workflow-safety requirements. These audits may include, without limitation, evaluation of Spark Message placements, contextual trigger accuracy, performance impact, data-handling practices, SDK/API configuration, and adherence to clinical-workflow guidelines.

Publishers must provide timely and reasonable access, documentation, system visibility, technical support, and any information necessary to facilitate such audits, including access to integration logs, reporting dashboards, workflow recordings, or other monitoring tools relevant to Spark Platform performance and safety. Failure to fully cooperate with an audit, including delays, withheld information, or technical obstruction, may result in immediate suspension or termination from the Program, forfeiture of accrued payments, deactivation of Spark Messages, and the pursuit of additional legal or equitable remedies available to Doceree.

13. Amendments

Doceree reserves the right to amend, modify, or update this Policy at any time in its sole discretion. Such amendments may include, without limitation, changes to prohibited content, Spark Platform workflow requirements, contextual trigger logic rules, technical specifications, operational standards, compliance obligations, or enforcement procedures. Amendments may also reflect updates necessary to ensure ongoing alignment with applicable laws, clinical workflow expectations, or changes implemented within EHR or health system environments.

Material changes will be communicated to Publishers through appropriate channels. Continued participation in the Program or continued use of the Spark Platform following any amendment constitutes acceptance of the revised Policy. Publishers are responsible for reviewing this Policy regularly to ensure ongoing compliance with all updated Spark integration requirements.

14. Grievance and Contact

Publishers or users who have questions, concerns, or complaints regarding this Policy, the placement or behavior of Ads or Spark Messages, contextual trigger accuracy, workflow impact, data-handling practices, or any other compliance matter may submit a written notice to Doceree’s legal team. Notices must include sufficient detail to allow proper investigation, including the relevant Publisher Property URL(s), the affected EHR or health system module (if applicable), a description of the issue, workflow screenshots or logs, and any supporting documentation. All communications should be sent to:

  • Email: legal@doceree.com
  • Address: Doceree Inc., 150 John F Kennedy Parkway, Suite 403, Short Hills, NJ 07078, USA

Doceree will review and respond to all submissions in a timely manner. Publishers are expected to cooperate fully with any inquiries, audits, or remedial requests arising from such grievances, particularly those relating to clinical workflow safety, contextual trigger integrity, or prohibited Spark Message placement.