At Incite Health, Inc., we take your privacy seriously, and will only use your personal information for professional purposes as defined in this policy. This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use our services, and tells you about your privacy rights and how the law protects you.
By using our services, you agree to the collection and use of information in accordance with this Privacy Policy.
The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. For the purposes of this Privacy Policy:
Incite Health may collect personal information (data) about you, which could include your full name, phone, fax, or cell phone number, email address, the company for which you work, the position you hold, or your resume. Incite Health only collects the information if you provide it via email, business card or phone call, or employment application.
Incite Health may process personal data. Processing is defined as any operation which is performed on personal data; this may include collection, recording, organizing, structuring, storing, adapting or altering, retrieving, consultation use, disclosing by transmission, disseminating or otherwise making available, alignment or combination, restriction, erasing, or destroying.
Under data privacy laws, Controllers decide the reasons and necessity for processing data, and Processors process data in accordance with the instructions of the Controller, on their behalf.
Incite Health may act as the Controller or as the Processor when your personal data is being used. Throughout this Privacy Policy, we explain whether we are acting as a Controller or a Processor with respect to each activity outlined.
If you choose not to provide us with your personal data, Incite Health may not be able to provide you with any of our services, process your employment application, or respond to communications from you via our website. If we ask for personal data which is a contractual requirement or which is needed to comply with our legal obligations, we will inform you.
Additional privacy terms tailored to different methods of data processing by business lines and operations may apply to personal information shared with Incite Health. If alternative privacy terms are provided to you for a specific purpose, those terms will govern the processing of personal data in relation to that purpose.
This Privacy Policy describes how Incite Health collects, receives, uses, stores, shares, transfers, and processes your personal information, as well as your rights in determining what we do with the information we collect or hold about you.
If at any time you have questions about our practices or any of your rights as described herein, you may contact our Data Protection Officers at privacy@incitehealth.com. This inbox is actively monitored and managed by personnel trained in our policies, processing, and handling of personal data.
In order to deliver the information or services offered by our company and website, including www.incitehealth.com, we may need personal information from you, such as your email address. The data about you Incite Health collects, uses, and shares depends on who you are and how we interact with you.
Generally, the information collected from you via our website is limited to email address, phone number, the company you work for, and the position you hold. An exception is your application for an employment opportunity, which may include other personally identifying information as provided by you; this is described in a future section.
We collect information in several ways:
Incite Health’s website use cookies, which are data files placed by a website operator on the hard drive of the computer visiting the website. Incite Health may place cookies on the computers of visitors to the Incite Health website to allow the website to provide the service requested, to remember repeat visitors, to improve the user experience of the website, to allow the company to obtain site analytics, and to serve and adjust our marketing messages on our websites and elsewhere on the internet, based on the visitor’s previous browsing activity.
We only use cookies based on your consent, with the exception of cookies that are strictly necessary to provide you with the services you have requested. We do not permit third parties to track you from our site across other sites to deliver advertising or other content.
If you do not want non-essential cookies placed on your device, you can accept or reject them in the cookie notices. Otherwise, most browsers will allow a visitor to choose which cookies can be placed on their computer, and to delete or disable cookies. Please note that disabling cookies may prevent a visitor from using certain features of the Incite Health website. For more information, please refer to the cookie policy on the website.
Incite Health may use your personal information for the following purposes, which are in our legitimate business interests:
If we process your personal information under consent provided by you, you have the right to withdraw that consent at any time. Your withdrawal of consent, however, will not affect the lawfulness of any processing we have undertaken before the withdrawal. We may process your personal information where necessary for our compliance with a legal obligation. Finally, in some cases, we process your personal information as necessary to perform a contract with you or to take steps that you request before we enter into a contract.
Under data protection laws around the globe, certain types of personal data, sensitive or special category data require enhanced protection. These include a requirement that the national law of the country specifically allows the processing of that data, or more enhanced security applied to the data, or that the personal data processed may improve the health of people in that country. The laws vary around the countries we work in, and we respect the national law and adhere to the rules around the processing of sensitive data.
In connection with our recruiting processes and programs, we process your personal data in accordance with this policy. If such processing conflicts with the requirements of specific national law, that applicable law will prevail.
To apply for a position on our site, we will collect personal data about you (e.g., name and phone number) and your professional experience, education, and training (e.g., resume). Upon offer of employment, examples of data collected are your name and any former names, address, email, contact information, universities attended, professional certification work, educational history (e.g., resume, CV), references, achievements, and copies of identification documents. Upon employment, your photo will be taken.
We process your personal data for necessary human resources and business management reasons, including identifying and evaluating candidates for potential employment, as well as for future roles that may become available; recordkeeping in relation to recruiting and hiring; ensuring compliance with legal requirements, including any diversity and inclusion requirements and practices; conducting background and criminal history checks as permitted by applicable law. We may also analyze your personal data or aggregated/pseudonymized data to improve our recruitment and hiring process and augment our ability to attract successful candidates.
We may desire to retain your personal data to consider you for future employment opportunities. In such an event we will seek your consent to be part of our future job alerts. If you consent to future job alerts, but subsequently wish to withdraw, please contact us at the privacy email addresses listed above.
Your personal data may be accessed by recruiters and interviewers in the country where the position for which you applied is based or by recruiters and interviewers in different countries within our organization.
Individuals performing administrative functions and IT personnel within our organization may also have a limited access to your personal data in order to perform their jobs. We have put in place legal mechanisms designed to ensure protection of your personal data that is processed by us, including the transfer of it to countries other than the one in which you reside.
We may use third party service providers to provide a recruiting software system. We may also share your personal data with other third-party service providers that may assist us in recruiting talent, administering, and evaluating pre-employment screening, background checks and testing, and improving our recruiting practices.
We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Notice and protects the confidentiality, availability, and integrity of your personal data.
If you accept an employment offer, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with specific country requirements and our data protection and other workplace policies, which will be provided to you at that time.
Upon employment, we may share your internal CV with any client of ours whose study you may work on, or with any Sponsor auditor or regulatory auditor who requests training records as part of an audit.
Incite Health is a multidisciplined, high complexity, clinical laboratory supporting clinical trials, medical research studies of Sponsors (i.e., the companies conducting the clinical trials) and diagnostic needs across a spectrum of patients, institutions and organizations. In relation to Incite Health’s delivery of CRO services to Sponsors, the Sponsor is in control of how and why your personal data is processed and is therefore the Data Controller; Incite Health is a Data Processor. The purposes for which clinical trial participants’ personal data will be used by study sites and Sponsors will depend on the nature of the study and will be addressed in more detail in study-specific documentation provided to patients by the Sponsor. As such, participants should look to that document to understand how their personal data is processed.
For Incite Health’s purposes of bioanalytical and biomarker services, study data is pseudonymized, meaning names and other identifying information are excluded. Instead, participants are identified by a code or Subject ID. Incite Health’s role as Data Processor may include the transfer of such information to the applicable Sponsor, its corporate affiliates, business partners, and third-party service providers performing services related to the study.
In order to provide services or purchases, or to provide information about Incite Health’s capabilities and offerings, we will use personal data collected from you to provide the requested information and process requested transactions. We may also use personal data to improve the quality of our services, send and receive communications about Incite Health services, and to enable our business partners and agents to perform activities on our behalf to meet your inquiry or provide services.
For individuals engaged by Incite Health clients and collaborating with Incite Health in connection with projects where Incite Health is providing services, personal data may be used by Incite Health to carry out the applicable services and related services (e.g., client name and contact details).
If you are a customer, or if you request or indicate an interest in information about our services, we may process your name, email address, phone number, job title, information about the company where you work, including website address, postal address, job title and function, company size and financial information, comments you provide, and information about which of our services you use, or which may be of interest to you. We maintain and update this information as we continue to engage with you, and we process personal information about individuals to fulfill our obligations under contract or agreement, or as required in support of financial auditors hired by Incite Health.
Vendor representatives may share personal data with Incite Health to provide information about services, such as business support and laboratory products and services, which may be available through a vendor. Incite Health will use any personal data provided by the vendor and its representatives to receive and assess the vendor information, products, and services. Uses may include processing for requested transactions, reviewing the quality of the vendor’s services, sending and receiving communications about the products and services available through the vendor, and enabling Incite Health’s business partners, consultants, clients, and agents to perform activities and make decisions in relation to the vendor.
For vendors engaged by Incite Health, including in relation to research studies being managed by Incite Health and its clients, your personal data may be used by Incite Health to carry out the projects, activities, and other related services in connection with which the vendor is engaged by Incite Health. This may include the transfer of such personal data to the applicable Incite Health study sponsor or client, other vendors involved in a project for which a vendor is engaged and such parties’ respective corporate affiliates, business partners and third-party service providers performing services or activities related to the project or activities for which a vendor is engaged by Incite Health.
Incite Health processes personal data it holds about you in accordance with applicable legal provisions in Europe, most particularly the European Union General Data Protection Regulation (EU GDPR). The personal data we hold are either retained at our French or Italian sites or are transferred to countries benefitting from an adequacy decision from the European Commission, or to the United States. Data transferred to the United States are strictly held by Incite Health’s secure servers and used for internal business purposes under global corporate policies.
Incite Health uses external services for its customer relationship management and its external communication tools such as newsletters and e-mail. Any personal data sharing with sub-contractors acting for Incite Health is carried out in accordance with legal provisions in France or Italy, and in Europe and within boundaries strictly defined by the purpose of the processing.
In cases where we need your consent to process your personal data, we will ask you to make a positive identification (e.g., to check a box, sign a document, provide information electronically) that you agree to processing. By providing consent, you are stating that you have been informed as to the nature, purpose, scope, and duration of our processing. Where we rely on consent to process your information, you have the right to withdraw that consent for that activity at any time.
In cases in which you have entered into a contract with Incite Health, we may process your personal data because it is necessary to deliver the service you have requested, you are employed by us, or if you provide a service to us.
Laws in the United States differ from the laws applicable to European countries. We take appropriate steps to ensure that personal data is processed, secured, and transferred according to applicable law. Where we transfer personal data from the European Economic Area to the US, which does not offer the same level of data privacy protection, we have ensured appropriate safeguards are in place via internal corporate policies regarding encryption and restriction of access.
As a global business, it may be necessary to transfer personal data within Incite Health businesses and with agents, contractors, or partners of Incite Health. These agents, contractors, or partners are restricted from using this data in any way other than to provide services for Incite Health. Incite Health may, for example, provide your personal data to agents, contractors, or partners for hosting our databases, for data processing services, or so that they can send you information that you requested.
Incite Health may be required to share personal data in response to an authorized information request by governmental authorities or where required by law.
As part of, or during negotiations of, any merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business or assets (including as part of any bankruptcy or similar proceedings), we may transfer personal data to other parties involved in these transactions. Under these circumstances, all parties have entered into a confidentiality agreement and are obligated to protect any information provided as part of the transaction and not to use the personal data for any purpose other than the purpose for which it was collected.
Incite Health will not retain your personal information longer than necessary for the pursued purpose and in accordance with applicable legal provisions in France, Italy, or any other applicable international laws. Incite Health retains personal data for as long as it is necessary in accordance with its business, contractual, legal, and regulatory requirements. Where appropriate and consistent with regulatory requirements, Incite Health engages its professional Quality Assurance department to safeguard the accuracy of data. In general, our Privacy Policy and procedures provide individuals easy means of validating, correcting errors, and updating information.
When we collect information that is not personal information or convert personal information into information which can no longer be used to identify you (such as through aggregation or anonymization), we may use and disclose that information for any purpose, as unidentifiable data is not covered under data protection laws.
Incite Health may use personal data it receives from Sponsors and business customers to provide laboratory services for and under the direction of its business customers who act as the Data Controllers. We will keep personal information about you for as long as we provide these services. We will retain personal information as long as you work for or with us, or as long as we are addressing a concern, question, complaint, or request you have made to us, as applicable to our interactions with you. If we have a contract or other agreement with a customer, we will follow the retention obligations of that agreement.
We may keep data longer if we have a legal obligation to keep it or to maintain necessary records for legal, financial, compliance, or other reporting obligations, and to enforce our rights and agreements. When we no longer need personal data, we securely delete or destroy it.
While Incite Health does all that we can to secure your personal data, the sending of information over the internet is not completely secure; therefore, you do this at your own risk. Once we receive your personal information, we implement strict security procedures to prevent unauthorized access.
Incite Health uses means of prevention, rules, and technological processes to ensure the protection against any unauthorized access, fraudulent use, alteration, disclosure, loss, or destruction of your personal information, considering the risks involved and the nature of the personal information. We also have implemented measures to maintain the ongoing confidentiality, integrity, and availability of the systems and services that process personal information and will restore the availability and access to data in a timely manner in the event of a physical or technical incident.
Incite Health ensures appropriate technical and organizational measures are taken to protect personal data from unauthorized or unlawful processing and to protect against accidental loss, destruction, or damage. Incite Health’s website and electronic databases have security measures in place to protect the loss, misuse, unauthorized access or disclosure, alteration, or destruction of the information under our control. However, as effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the internet. We have a privacy incident response program designed to promptly respond to and escalate all privacy-related questions, complaints, or concerns, including any potential privacy or security incident.
If you have questions about the security of your personal information, or if you have reason to believe that the personal information that we hold about you is no longer secure, please contact us immediately as described in this Privacy Policy.
Incite Health reserves the right to take appropriate legal action, including without limitation, referral to law enforcement, for any illegal or unauthorized use of this Website. We also reserve the right take any action to prevent the unauthorized use of our intellectual property rights.
We may cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity of or locate anyone for the prevention or detection of crime or the apprehension or prosecution of offenders. There may be other circumstances in which we may be required by law to disclose information about you or your use of this Website. You waive and hold us harmless from any claims resulting from such disclosures and from any actions taken as a consequence of investigations by either us or law enforcement authorities.
Incite Health may investigate any complaints or reported breaches of this Privacy Statement Policy and take any action that we deem appropriate (which may include, without limitation, removing any of your information, issuing warnings, suspending, restricting, or terminating your access to this Website). We also reserve the right at our discretion to suspend, restrict, or terminate your access to this Website at any time without notice if we have reasonable grounds to believe that you have breached this Privacy Statement Policy or our Terms of Use.
Incite Health does not seek information from individuals under 16 years of age, and no information should be submitted to Incite Health by anyone under 16 years of age.
You may lodge a complaint pertaining to the application of your rights by contacting the concerned supervisory authorities.
You have rights in respect of your personal data. Our Global Policy is to extend the rights listed below to all our data subjects worldwide unless the local law states otherwise.
If you feel your data protection rights have been infringed by Incite Health, you have the right to complain to your local data protection supervisory authority.
For any concern about the privacy of the personal data we hold about you or request regarding the application of your personal rights, please contact us at privacy@incitehealth.com, or by calling 888-417-1363 or writing to:
Incite Health, Inc.
Attn: Data Protection Officer
3805 Old Easton Road
Doylestown, PA 18902
Incite Health reserves the right to revise the current Privacy Policy at any time. The Privacy Policy will be regularly updated. When we update it, for your convenience, we will make the updated Privacy Policy available on the website page, and we recommend that you check the latest version on a regular basis. Please review the Privacy Policy from time to time to check whether we have made any changes to the way in which we use your personal information.
This Policy does not create any legal rights or obligations and Incite Health reserves the right to modify or amend this Policy. For instance, it may need to change as new legislation is introduced or as legislation is amended. Where we have your contact details, we may notify you of material changes. We will post a notice on our home pages that this Privacy Policy has changed.