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 Notice 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-General Data Protection Regulation (GDPR)
• EU-US 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)

This notice 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. The details provided within this notice are in alignment with the Data Intensity Privacy Policy.

This notice 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.)

Data Intensity has adopted policies to establish and maintain an adequate level of Personal Data privacy protection. This notice details provisions that apply to the processing of Personal Data that Data Intensity obtains from Customers operating in the European Union.

Data Intensity has aligned globally with the General Data Protection Regulation (GDPR) regarding the collection, use, and retention of personal information from not just Customers residing in the European Union member countries, but all customers globally.

For US operations, Data Intensity participates in the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce to provide an adequacy judgement. Data Intensity has certified that it adheres to the GDPR and 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 privacyshield. The Federal Trade Commission (FTC) has jurisdiction over Data Intensity’s compliance with the Privacy Shield.

Data Intensity has designated a Privacy Officer (who acts as Data Protection Officer) to oversee its Privacy program including compliance with the General Data Protection Regulation (GDPR) as well as EU-US and Swiss-US Privacy Shield programs. The Privacy Officer shall review and approve any material changes to these programs as necessary.

Privacy and Data Protection Officer: Christopher Beatty

Phone Number: +1 877-687-3227

Email: privacy@dataintensity.com

Mailing Address:
Data Intensity
ATTN: Privacy Department
22 Crosby Drive
Suite 100
Bedford, MA 01790

Data Intensity will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist Data that it processes. Data Intensity personnel will receive training, as applicable, to effectively implement these provisions. Please in protecting the Personal refer to Section 7 for a discussion of the steps that Data Intensity has undertaken to protect Personal Data.

Data Intensity provides various solutions to its Customers who purchase its products or services. Data Intensity collects Personal Data from Individual Customers when they purchase its products, register with our website, log-in to their account, complete surveys, request information or otherwise communicate with us.

The Personal Data that we collect may vary based on the Individual Customer’s interaction with our website and request for our services. As a general matter, Data Intensity collects the following types of Personal Data from its Individual Customers: contact information, including, a contact person’s name, work email address, work mailing address, work telephone number, title, and company name. Individual customers have the option to log into their accounts online and to request service online or over the phone, we will collect information that they choose to provide to us through these portals. Failure to provide this information will result in Data Intensity’s inability to coordinate with the individuals on provided services.

When Individual Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website.

The information that we collect from Individual Customers is used for selling the products and services they buy from us, managing transactions, reporting, invoicing, renewals, other operations related to providing services and products to the Individual Customer. Data Intensity does not resell any marketing contact data to any other party, however may utilize 3rd Party marketing companies to perform marketing communications.

For certain products and services, Data Intensity serves as a service provider. In our capacity as a service provider, we will receive, store, and process any form of Personal Data including sensitive data. In such cases, we are acting as a data processor and will process the personal information on behalf of and under the direction of our partners and/or agents. The information that we collect from our Individual Customers in this capacity is used for managing transactions, reporting, invoicing, renewals, other operations related to providing services to the Individual Customer, and as otherwise requested by our partner and/or agent.

Data Intensity uses Personal Data that it collects directly from its Individual Customers and for its partners indirectly in its role as a service provider for the following business purposes, without limitation:

• maintaining and supporting its products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including managing transactions, reporting, invoices, renewals, and other operations related to providing services to an Individual Customer);

• satisfying governmental reporting, tax, and other requirements (e.g., import/export);

• storing and processing data, including Personal Data, in computer databases and servers located in the United States;

• verifying identity (e.g., for online access to accounts);

• as requested by the Individual Customer;

• for other business-related purposes permitted or required under applicable local law and regulation;

• and as otherwise required by law.

Data Intensity does not collect Sensitive Data from its Individual Customers but may act as a Data Processor of Customers Sensitive Data in the course of providing services.

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:

• execute a Data Processing Agreement (DPA) agreeing to provide adequate protections for the Personal Data that are no less protective than those set out in the Data Intensity Privacy Policy and either

• reside in the EEA;

• or adhere to the EU-US or Swiss-US Privacy Shield principles and be an active member;

• or execute a Data Processing Agreement (DPA) Model Contractual Clauses as defined by the EU

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 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 the time.

Data Intensity maintains provisions in its Privacy Policy detailing the maximum retention period for personal data on the various categories of data subjects. This period is based on the various business need and regulatory requirement to retain the data. Additionally, Data Intensity maintains procedures for the purging of the data once the retention period has passed.

Data Intensity notifies Individual Customers about its adherence to the EU-US and Swiss-US Privacy Shield principles through this publicly posted website privacy notice, available at: data intensity website and take Individual customers approval and adherence to the current policy when they provide their information to us.

Data Intensity provides an annual transparency report detailing the number of requests or orders from governments and courts for access to customer data. When a request is received, Data Intensity reviews it thoroughly and only provide information within the scope and authority of the request. Data Intensity also ensures that the request follows company policies and applicable law.

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.

Right to Access and Portability.

Individual Customers have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which Data Intensity collected it. Individual Customers may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and Data Intensity policies. Upon reasonable request and as required by GDPR and Privacy Shield, Data

Intensity allows Individual Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Individual Customers may edit their Personal Data by logging into their account profile or by contacting Data Intensity by phone or email.

Additionally, the data subject may ask to obtain and reuse their personal data in a safe and secure way. The data will be provided in a structured, commonly used and machine-readable format.

In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a written request to the Data Intensity Corporate Headquarters.

Requests for Personal Data.

Data Intensity will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise:

• (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation;
• or (b) requests received from the Data Subject. If Data Intensity receives a request for access to his/her Personal Data from an Individual Customer, then, unless otherwise required under law or by contract with such Individual Customer, Data Intensity will refer such Data Subject to the Individual Customer. Satisfying Requests for Access, Modifications, and Corrections.

Data Intensity will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.

Individual Customer’s may also update your Personal Information tied to a personal Data Intensity account by using our self-service tool or upon request by contacting your Service Manager or emailing privacy@dataintensity.com. If you should become aware that your Personal Information with Data Intensity is not complete and accurate, you should promptly update or notify us to update your information.

Request to Restrict Processing.

Individuals may request the restriction or suppression of personal data, however this only applied in certain circumstances. When processing is restricted, Data Intensity may store but not utilize the data subject’s personal data. Data Intensity will inform any data subject prior to lifting restrictions on processing.

Individual customers may contact Data Intensity with questions or complaints concerning this notice at the following address: privacy@dataintensity.com

In compliance with the GDPR and EU-US and Swiss-US Privacy Shield, Data Intensity commits to resolve complaints about your privacy and our collection or use of your personal information. EU individuals with questions or concerns about the use of their Personal Data should contact us at: privacy@dataintensity.com.

If a Customer’s question or concern cannot be satisfied through this process Data Intensity has further committed to refer unresolved privacy complaints under GDPR and EU-US and Swiss-US Privacy Shield requirements to an EU Data Protection Authority or Swiss Federal Data Protection and Information Commissioner (FDPIC). Data Intensity is registered with the United Kingdom Information Commissioner’s Office (UK ICO).

If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by Data Intensity, EU individuals may bring a complaint before the UK ICO. Information about how to file a complaint before the UK ICO program can be found here. Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel as a binding arbitration mechanism for US operations.

Data Intensity commits to cooperate with EU data protection authorities (DPAs) and Swiss Federal Data Protection and Information Commissioner (FDPIC) to comply with the advice given by such authorities regarding human resources data transferred from the EU in the context of the employment relationship.

If a Customer’s question or concern cannot be satisfied through this process and the customer is a resident of the Commonwealth of Massachusetts, the customer should direct complaints to the Consumer Affairs and Business Regulation office, details of which can be found here

“Cookies” are small text files that are placed on your computer by websites that you visit. They are widely used to make websites 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.

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.

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.

Data Intensity will conduct an in-house verification at least annually to ensure that its attestations and assertions regarding 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 the Data Intensity Privacy Policy, as well as this Privacy Notice and its publicly posted website privacy notice to ensure that these policies accurately describe the practices regarding the collection of Individual Customer Personal Data
• Ensure that the publicly posted privacy notice informs Individual Customers of Data Intensity’s commitment to GDPR and participation in the EU-US and Swiss-US Privacy Shield programs and where to obtain a copy of additional information.
• Ensure that this Notice and the Privacy Policy continues to comply with the principles laid out in Privacy Shield and GDPR.
• 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 training for Employees about Data Intensity’s adherence to GDPR and participation in the Privacy Shield programs and relevant policies and procedures supporting the appropriate handling of Individual’s Personal Data

Data Intensity will prepare an internal verification statement on an annual basis.

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