Privacy Policy

Data Intensity is committed to safeguarding the privacy of individual customers, customer representatives and sensitive data provided by our customers in the course of providing services. Data Intensity has adopted this Privacy Policy (“Policy”) to establish and maintain an adequate level of Personal Data and Sensitive Data privacy protection and to demonstrate Data Intensity’s information gathering and dissemination practices in accordance with the following laws and regulations:

  • EU-U.S Privacy Shield Framework
  • Swiss-US Privacy Shield Framework
  • Massachusetts 201 CMR 17.00: Standards for the Protection of Personal Information of Residents of the Commonwealth.
  • Health Insurance Portability and Accountability Act (HIPAA)
  • Categories
    Scope
    This Policy applies to the processing of Personal Data and Sensitive Data that Data Intensity receives about, and in the course of providing products and services with, its customers.

    This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)
    Privacy Shield
    Data Intensity has adopted this policy to establish and maintain an adequate level of Personal Data privacy protection. This Policy includes provisions that apply to the processing of Personal Data that Data Intensity obtains from Customers operating in the European Union.

    Data Intensity complies with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Individual Customers in the European Union member countries. Data Intensity has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.

    The Federal Trade Commission (FTC) has jurisdiction over Data Intensity’s compliance with the Privacy Shield.
    Responsibilities and Management
    Data Intensity has designated a Privacy Officer to oversee its Privacy program including compliance with the EU-US and Swiss-US Privacy Shield programs. The Privacy Officer shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to privacy@dataintensity.com.

    Data Intensity will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it processes. Data Intensity personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that Data Intensity has undertaken to protect Personal Data.
    Renewal/Verification
    Data Intensity will renew its EU-US and Swiss-US Privacy Shield certifications annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.

    Prior to the re-certification, Data Intensity will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Individual Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, Data Intensity will undertake the following:

  • Review this Privacy Shield policy and its publicly posted website privacy policy to ensure that these policies accurately describe the practices regarding the collection of Individual Customer Personal Data
  • Ensure that the publicly posted privacy policy informs Individual Customers of Data Intensity’s participation in the EU-US and Swiss-US Privacy Shield programs and where to obtain a copy of additional information (e.g., a copy of this Policy)
  • Ensure that this Policy continues to comply with the Privacy Shield principles
  • Confirm that Individuals are made aware of the process for addressing complaints and any independent dispute resolution process (Data Intensity may do so through its publicly posted website, Individual Customer contract, or both)
  • Review its processes and procedures for training Employees about Data Intensity’s participation in the Privacy Shield programs and the appropriate handling of Individual’s Personal Data

  • Data Intensity will prepare an internal verification statement on an annual basis.
    Disclosures/Onward Transfers of Personal Data
    Except as otherwise provided herein, Data Intensity discloses Personal Data only to Third Parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.

    Data Intensity may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, Data Intensity may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by Data Intensity and they must either:

  • comply with the Privacy Shield principles or another mechanism permitted by the applicable EU & Swiss data protection law(s) for transfers and processing of Personal Data;
  • or agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy;

  • Data Intensity also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure. Please be aware that Data Intensity may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Data Intensity is liable for appropriate onward transfers of personal data to third parties.

    In the event these providers may have access to personal or sensitive data of residents of the Commonwealth of Massachusetts, these Third Parties must be capable of maintaining security measures consistent with Massachusetts 201 CMR 17.

    Any Third Party that may have access to Personal Health Information that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions for customers are required to sign a Business Associate Agreements in compliance with the Health Insurance Portability and Accountability Act.
    Data Integrity and Security
    Data Intensity uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. Data Intensity has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to Data Intensity’s electronic information systems requires user authentication via password or similar means. Data Intensity also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.

    Further, Data Intensity uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.
    Accessing Personal Data
    Data Intensity personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
    Cookies
    “Cookies” are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently. Data Intensity and its marketing partners or suppliers may use cookies or other technologies when you interact with the website or use the Products. If you do not wish to utilize cookies, please adjust your browser settings appropriately but the functionality of this or other sites may be adversely impacted.
    Third Party Sites
    Some of our services are provided through sites that bear our partners’ or suppliers’ names and trademarks and are not in our control, and this website may contain links or other devices that take you to other websites that are also not in our control. Certain of those other websites may provide products or services to you directly or on our behalf. Data Intensity is not responsible for any aspect of other websites, including, without limitation, the privacy practices, products, services, or content of such websites. This Privacy Notice will not apply to such other websites. Rather, your activity and the information that you provide at such other websites will be subject to the Privacy Notice and other terms and conditions posted at such other websites.
    Enforcement
    Failure for Data Intensity personnel, contractor, or Third Party to comply with the terms in this privacy policy or to jeopardize the privacy of individual data will result in an investigation and recourse up to and including termination and canceling of contract.

    Failure for Data Intensity as an organization to adhere to the privacy principles may result in regulatory findings, suspension and removal of Privacy Shield, publicity for findings of non-compliance and damages awarded where prudent to the affected data subject(s). In addition, the data subject may require the affected data to be deleted and appropriate evidence provided.
    Defined Terms
    Capitalized terms in this Privacy Policy have the following meanings:

    “Individual Customer” means an Individual customer or client of Data Intensity from EU or Switzerland. The term also shall include any individual agent, representative, of an individual customer of Data Intensity and all employee of Data Intensity where Data Intensity has obtained his or her Personal Data from such Individual Customer as part of its business relationship with Data Intensity.

    “Data Subject” means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.

    “Employee” means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of Data Intensity or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.

    “Europe” or “European” refers to a country in the European Union.

    “Personal Data” as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual’s name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term “person” includes both a natural person and a legal entity, regardless of the form of the legal entity.

    “Sensitive Data” means Personal Data that discloses a Data Subject’s medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.

    “Third Party” means any individual or entity that is neither Data Intensity nor a Data Intensity employee, agent, contractor, or representative.
    Changes to this Policy
    This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.

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