INC Research, LLC (“we”, “us” or “INC Research”) knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. We want you to understand the types of information we collect, how we use that information, how we secure it, and how we share it.
1. Information We Collect
Through your interaction with and use of the Sources, INC Research may collect Personal Information, which is information that identifies an individual or relates to an identifiable individual. Personal Information may include, but is not limited to, your name, physical address, telephone number, e-mail address, company affiliation and associated interests.
INC Research may also collect other information through your interaction with and use of the Sources, which does not reveal your specific identity or does not directly relate to an individual. This other information may include, but is not limited to, browser and device information, data collected through automated electronic interactions, application usage data, demographic information, geographic or geo-location information, statistical and aggregated information.
Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users in a particular zip code.
In some instances, we may combine Personal Information with other information, such as combining a precise geographical location with your name. If we combine Personal Information with other information, we will treat the combined information as Personal Information.
2. How We Collect Information
INC Research collects information in a variety of ways that fit broadly into the following general categories:
- Direct Interactions: From your use of and interaction with us through the Sources and other activities such as sales inquiries and transactions.
- Publicly Available Data / Data from Third Parties: Other data you may have made publicly available, such as social media posts, or data provided by third party sources, such as marketing opt-in lists, or data aggregators.
- Automated Interactions: From the use of technologies such as cookies and other tracking technologies.
Cookies: "Cookies" (which may be html files, Flash files or other technology) are text files that help store user preferences and activity. "Web beacons" (also known as image tags, gif or web bugs) are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising responses. The Sources and/or third parties may use “cookies”, “web beacons” and other similar tracking technologies (collectively, “Tracking Technologies”) to collect information from you automatically as you use the Sources, browse INC Research websites and the web.
Other Tracking Technologies: We use Tracking Technologies to help tailor our content, understand website and internet usage, improve or customize the content, offerings or advertisements through the Sources, personalize your experience with respect to the Sources (for example, to recognize you by name when you return to an INC Research website), save your password in password-protected areas, save your online video player settings, help us offer you programs or services that may be of interest to you, deliver relevant advertising, maintain and administer the Sources and for other purposes described in the "Uses of Information".
These Tracking Technologies collect “click stream” data and information regarding your use of the Sources, such as your visits, use of our features, and preferences and may also collect your IP address or some other identifier unique to the device you use to access the Sources (“Identifier”). Your Identifier may be automatically assigned to the device you use to access the Sources. By using the Sources, whether as a registered user or otherwise, you acknowledge, understand and hereby agree that you are giving us your consent to track your activities and your use of the Sources through these Tracking Technologies.
INC Research’s use of Automated Interactions may change over time as technology evolves. The descriptions above are designed to provide you with some detail about INC Research's current approach to information collected from Automated Interactions.
3. Use of Information
Disclosure to Third Parties
In addition to aggregate information (discussed previously), we may share some kinds of Personal Information with third parties as described below.
- Companies and people who work for us: We contract with other companies and individuals to help us provide services including the Sources. For example, we may host some of our Sources on another company's computers, hire technical consultants to maintain our sites, or work with companies to remove repetitive information from customer lists, analyze data, provide marketing assistance, and provide customer service. In addition, we may validate your identity and other information against available databases. In order to perform their jobs, these other companies may have limited access to some of the Personal Information we maintain about our users. Other companies may collect information on our behalf through their web sites. We require that such companies not use your information for any purpose other than fulfilling their responsibilities to us. We also require that such companies keep your Personal Information confidential and to comply with applicable laws. INC Research cannot, however, guarantee that any third party will maintain the privacy of your information.
- Promotional and informational offers: Sometimes we send offers to selected groups of users. To accomplish this we may use third parties working on behalf of INC Research. We provide a variety of mechanisms for you to tell us you do not want to receive such promotional - informational offers. For example, we may provide an opt-in box for customers to receive information that is sent by a third-party fulfillment house, and we make clear that, by opting in, you are submitting your data to a third-party. You can elect not to receive promotional or informational material from us by following the instructions to opt-out as mentioned or included in each of our programs we send to you.
- Business transfers: If we transfer a business unit or an asset (such as an INC Research website) to another company, we may transfer the Personal Information we have collected to the relevant third party.
- Legal requirements: We may be obligated to cooperate with various law enforcement inquiries. INC Research reserves the right to share or transfer your information to comply with a legal requirement, disclose any activities or information about you to law enforcement or other government officials as we, in our sole discretion, determine necessary or appropriate, in connection with an investigation of fraud, for the administration of justice, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability. We may release information if, in our judgment the release may be necessary to prevent the death or serious injury of an individual.
While we cannot guarantee that such third parties will maintain the privacy of your information, we are potentially liable in cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield.
4. Sharing of Non-identifiable Information
5. Protection of information
The security of your Personal Information is very important to INC Research. We use commercially reasonable physical, electronic, and administrative safeguards that are designed to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. However, regardless of our efforts and the device you use to access the Sources, it is possible that third parties may unlawfully intercept or access transmissions or private communications over an unsecured transmission. In the event that your Personal Information is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, INC Research will notify you by e-mail, fax, or U.S. mail. INC Research will give you notice promptly, consistent with the reasonable needs of law enforcement and/or INC Research to determine the scope of the breach and to investigate and restore the integrity of the data system.
6. Your Privacy Choices
Personal Information Opt-Out
Informational/Promotional Email Opt-out
You may have an opportunity to elect to receive recurring informational/promotional e-mail from us. Our email correspondence will include instructions on how to update certain personal information and how to unsubscribe from our emails. Please follow the instructions in the emails to opt-out of an email. We will unsubscribe you from that newsletter or other programs within thirty business days.
You can always contact us at firstname.lastname@example.org in order to change your preferences with respect to marketing contacts.
7. Children's policy
We are committed to protecting the privacy of children. We do not collect personally identifiable information from any person we actually know is under the age of 18. If we learn that we have collected personal information from a person under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from a person under age 18, please contact us at email@example.com.
9. Notice for California Users
Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to that customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. To request the above information, please email us at firstname.lastname@example.org
or write to us at:
INC Research, LLC
Attn: Data Privacy Officer
3201 Beechleaf Ct
Raleigh, NC 27604
We will respond to such written requests within 30 days following receipt at the mailing address above. We reserve the right not to respond to requests submitted other than to the address specified above or otherwise exempted by law. Please note that we are required only to respond to each customer once per calendar year.
10. Access, Correction, and Updates
You may request to review, correct, update, delete, or otherwise modify any of your Personal Information that you have previously provided to us through the Sources, or object to the use, disclosure or processing of such Personal Information by us. If you have privacy concerns about your Personal Information, please contact our Global Privacy Officer at: email@example.com
Attn: Data Privacy Officer
3201 Beechleaf Ct
Raleigh, NC 27604
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us.
While the majority of questions and issues related to access can be handled quickly, complex requests may take more research and time. In such cases, issues will be addressed, or you will be contacted regarding the nature of the problem and appropriate next steps, within thirty days.
11. Retention and Deletion
At the end of the retention period, INC Research will delete your Personal Information in a manner designed to ensure that it cannot be reconstructed or read.
12. Cross Border Transfers and Privacy Shield
Related to its participation in the Privacy Shield Framework with both the EU and Switzerland, INC Research is subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”). In addition, INC Research is committed to cooperate with the EU Data Protection Authority (“DPA”) and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”). If you have a complaint about the collection or use of your Personal Information and would like to seek an independent recourse mechanism; in the EU, you may contact your local DPA and in Switzerland you may contact the FDPIC. A listing of each EU country’s DPA may be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm The FDPIC’s website may be found here: https://www.edoeb.admin.ch/?lang=en . You may also seek the possibility, under certain circumstances, for binding arbitration to resolve your complaint.
13. Sensitive Information
We ask that you not send us, and you not share any sensitive Personal Information (e.g., racial or ethnic origin, political opinions, financial background, religious or similar beliefs, sexual life, trade union membership or affiliations, individual medical records and history, physical, mental or physiological health condition or genetic or biometric information, ideological views or activities, information on social security measures, or administrative or criminal proceedings and sanctions which are treated outside pending proceedings).
- Service Terms address customer data to which we may be provided access in order to perform services.
- Recruiting Terms address information we may collect in connection with INC Research’s employment recruiting efforts.
15. Questions & Concerns
ATTN: Data Privacy Officer
3201 Beechleaf Ct
Raleigh, NC 27604
1. Customer Information and Services Data
Services Data: is data that resides on INC Research customer or third-party systems to which INC Research is provided access to perform services. INC Research treats services data according to these Service Terms, and treats services data as confidential in accordance with the terms of your agreement with INC Research for services.
2. How INC Research Collects and Uses Services Data
Below are the conditions under which INC Research may access, collect and/or use services data.
To Provide Services: Services data may be accessed and used to perform services under your agreement with INC Research for services. Any copies of services data created for these purposes are only maintained for time periods relevant to those purposes.
To Comply with Legal Requirements: INC Research may be required to retain or provide access to services data to comply with legally mandated reporting, disclosure or other legal process requirements.
INC Research may transfer and access services data globally as required for the purposes specified above. If INC Research hires subcontractors to assist in providing services, their access to services data will be consistent with the terms of your agreement with INC Research for services and these Service Terms.
INC Research does not use services data except as stated above or in your agreement with INC Research for services. INC Research may process services data, but does not control your collection or use practices for services data. If you provide any services data to INC Research, you are responsible for providing any notices and/or obtaining any consent necessary for INC Research to access, use, retain and transfer services data as specified in these Service Terms and your agreement with INC Research for services.
3. Access Controls
INC Research's access to services data is based on job role/responsibility. Services data residing in INC Research systems is controlled via an access control list mechanism.
4. Security and Breach Notification
INC Research is committed to the security of your services data, and has in place physical, administrative and technical measures designed to prevent unauthorized access to that information. INC Research security policies cover the management of security for both its internal operations as well as the services. These policies govern all areas of security applicable to services and apply to all INC Research employees.
INC Research is also committed to reducing risks of human error, theft, fraud, and misuse of INC Research facilities. INC Research's efforts include making personnel aware of security policies and training employees to implement security policies. INC Research employees are required to maintain the confidentiality of services data. Employees' obligations include written confidentiality agreements, regular training on information protection, and compliance with company policies concerning protection of confidential information.
INC Research promptly evaluates and responds to incidents that create suspicions of unauthorized handling of services data. Information Security and Legal are informed of such incidents and, depending on the nature of the activity, define escalation paths and response teams to address the incidents. If INC Research determines that your services data has been misappropriated (including by an INC Research employee) or otherwise wrongly acquired by a third party, INC Research will promptly report such misappropriation or acquisition to you.
Attn: Data Privacy Officer
3201 Beechleaf Ct
Raleigh, NC 27604
Your provision of personal information in connection with the recruiting or job application process confirms your consent for INC Research to collect that information and to use, transfer, retain and share it with third parties as specified in this policy.
1. Collecting Personal Information
You may provide personal information to INC Research including educational and employment background, contact information and preferences, job qualifications, and jobs for which you would like to submit an application. You also may choose to provide INC Research additional information, such as your CV, resume, or transcripts; employment references and related information; and compensation requests. In addition, INC Research may collect information from third parties in connection with a background or employment check and/or an employment reference.
2. Sensitive Personal Information
In connection with recruiting, INC Research does not require the disclosure of sensitive personal information concerning a person's racial or ethnic origin, political opinions, financial background, religious or similar beliefs, sexual life, trade union membership or affiliations, individual medical records and history, physical, mental or physiological health condition or genetic or biometric information, ideological views or activities, information on social security measures, or administrative or criminal proceedings and sanctions which are treated outside pending proceedings. If you have a disability and would like INC Research to consider any accommodation, you may provide that information during the recruiting process. As well, in some countries we ask for information such as race or ethnicity for the purpose of monitoring equal opportunity; however, we do not require applicants to provide race or ethnicity information, and if you provide this information it will not be viewable in the hiring or selection process. To the extent information you provide contains details of your racial or ethnic origin, political opinions, financial background, religious or similar beliefs, sexual life, trade union membership or affiliations, individual medical records and history, physical, mental or physiological health condition or genetic or biometric information, ideological views or activities, information on social security measures, or administrative or criminal proceedings and sanctions which are treated outside pending proceedings; job evaluations or educational records, you expressly authorize INC Research to handle such details as specified in these terms.
3. Voluntary Disclosure
Your provision of personal information in connection with recruiting is voluntary, and you determine the extent of information you provide to INC Research; please note that if you decide not to provide information, it may affect our ability to consider you for employment.
4. Using Personal Information
The information may be used to communicate with you, to manage INC Research's recruiting and hiring processes, to conduct ongoing compliance screening against publicly available watch and sanctions lists and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.
5. Cross Border Transfer and Privacy Shield
INC Research is a global corporation, with operations in over 47 countries, and has developed global data practices designed to assure your personal data is appropriately protected. Due to the global nature of INC Research's operations, your personal information may be stored, accessed, transferred or processed in countries globally, including the United States.
Related to its participation in the Privacy Shield Framework with both the EU and Switzerland, INC Research is subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”). In addition, INC Research is committed to cooperate with the EU Data Protection Authority (“DPA”) and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”). If you have a complaint about the collection or use of your Personal Information and would like to seek an independent recourse mechanism; in the EU, you may contact your local DPA and in Switzerland you may contact the FDPIC. A listing of each EU country’s DPA may be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. The FDPIC’s website may be found here: https://www.edoeb.admin.ch/?lang=en. You may also seek the possibility, under certain circumstances, for binding arbitration to resolve your complaint.
6. Data Recipients and Sharing with Third Parties
INC Research may share your personal information internally and with service providers and other third parties as necessary in connection with recruiting, employment, corporate governance, acquisitions and legal or regulatory requirements. INC Research requires that its service providers and such other third parties keep your personal information confidential and that they only use the personal information in furtherance of the specific purpose for which it was disclosed. While we cannot guarantee that such third parties will maintain the privacy of your information, we are potentially liable in cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield. INC Research and its service providers may use your personal information in an anonymized format (in a form in which your identity cannot be determined) for other purposes not specified above.
7. Security and Confidentiality
Except as otherwise stated in these terms or as required for legal or regulatory purposes, INC Research treats your personal information as confidential and will not disclose it to third parties without your consent. INC Research maintains, and requires its service providers to maintain, reasonable administrative, physical, and technical controls designed to protect the confidentiality and security of your personal information. INC Research employees who may have access to personal information are required to keep that information confidential. INC Research may employ security procedures at its facilities and on its computer systems to monitor and maintain security, including the use of closed circuit television. Any monitoring of INC Research facilities, systems or assets is performed in accordance with applicable law.
8. Retention and Access
INC Research may retain your information to consider you for other job opportunities. To the extent permitted or required by law, INC Research may delete data at any time; accordingly, you should retain your own copy of any information you submit to us.
You may access and correct personal information you have submitted to INC Research by contacting us at: firstname.lastname@example.org.
9. Your Responsibilities
You are responsible for the information you provide or make available to INC Research, and you must ensure it is honest, truthful, accurate and not misleading in any way. You must ensure that the information provided does not contain material that is obscene, defamatory, or infringing on any rights of any third party; does not contain malicious code; and is not otherwise legally actionable. Further, if you provide any information concerning any other person, such as individuals you provide as references, you are responsible for providing any notices and obtaining any consents necessary for INC Research to collect and use that information as described in these terms.
Attn: Data Privacy Officer
3201 Beechleaf Ct
Raleigh, NC 27604
Last updated: September 18, 2017