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290 - We are placing promotional branded banner ads (no claims) in third party HCP gated websites that will drive traffic to our own gated HCP specific website. The third party site is intended for HCP's only. a) As the third party site audience is validated to be HCPs only, is this sufficient to enable bypassing our gating mechanism and bringing the HCP directly into our site? b) We are intending to bring the HCP to our top level product overview page. For future use, are there any issues with deep linking the physician into other areas of the website? (ex: Dosing, patient support, safety)
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I presume from your question that both your banner and your website are product branded. I also presume that the banners have run of site in the third party website (optimally with exception rules as described in Q&A 283). With this understanding, here are the answers to your two questions: A) yes (provided the manufacturer has ensured that there is an appropriate mechanism which validates HCP status on the front end). B) There is no outright prohibition against linking such banner to pages other than the homepage. But as some specific linkages may not be appropriate, we should be informed of where the banner links to during the review for our initial assessment of the APS. We should also be informed if the content on that link destination page changes in time. For banner ads containing claims, please refer to the guidance documents on our website for web destination requirements relating to prescribing information and fair balance.
