Privacy Policy

Protecting your privacy is fundamental to the way Incentiv, Inc. (“Incentiv”, “we”, “us”, or “our”) conducts business. This Privacy Policy explains how we may collect, use and disclose your personal information when you access our digital or online properties or services that link to this Privacy Policy (including, our website (“Site”), our paid web application (“Web App”), our marketing activities, our live events, and other activities described in this Privacy Policy) (collectively, the “Online Services”). This Privacy Policy does not apply to your use of third-party sites linked to this website. 

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This Privacy Policy may change from time to time. We will make note of the changes on our website and your continued access to the Online Services is deemed to be your acceptance of those changes, so we encourage you to check back periodically for updates.

You can jump to particular topics by going to the headings below:

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• How We Collect or Receive Personal Information
• Disclosure of Personal Information
• Your Choices
• Data Security
• How We Retain Your Personal Information
• Other Important Information
• Contact Information

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We collect personal information in the course of providing the Online Services.

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.

How We Use Personal Information

We use the personal information which you provide to us to perform our Online Services as outlined in this Privacy Policy.  When you are our prospective or current business client of our Web App, we use personal information about you and your employees to: 

• deliver the Site and Web App;
• carry out "Know Your Client" checks and screenings prior to starting a new engagement;
• carry out client communications, services, billing, and administration;
• configure our Online Services and your dashboard access, and other professional services that you may request; 
• secure client feedback;
• deal with client complaints and requests;
• create marketing materials such as white papers, case studies, and social media content; or
• contacting and marketing to our clients.

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We also process personal information about our clients/prospective clients and employees of our clients/prospective clients to:

• contact our prospects and clients in relation to current, future and proposed engagements;
• send our prospects and clients newsletters, know-how, promotional material and other marketing communications; or  
• invite our prospects and clients to events (and arrange and administer those events).

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When you are a visitor to our Site, our Web App, attend our live events, or request marketing information, we may use your personal information to:

• monitor the performance of our Site and Web App, analyze trends, usage and activities in connection with our Site;  
• deliver targeted advertising where permitted by applicable law; or
• deliver information (including marketing information) to you based on your needs and interest.

Conducting data analytics

We are an innovative business, which relies on developing sophisticated products and services by drawing on our experience from prior engagements. We are not concerned with an analysis of identifiable individuals, and we take steps to ensure that your rights and the legitimacy of our activities are through the use of aggregated or otherwise de-identified data.

In delivering our Web App, the categories of personal information we use to conduct data analytics may include:

• Basic personal details, education, professional experience and affiliations, family, basic employment details and employee performance.
• Job titles, job roles, age, identified gender, identified ethnicity, identified race and individual performance levels.
• Compensation information related to the employees of our client companies, including, but not limited to, base salaries, allowances, bonuses, terms of employment, and long-term cash and equity incentives
• Other relevant information that may be needed to perform our work, such as occupation, language, zip code, area code, location, and the time zone.

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We use Google Analytics on our Site and Web App, you can find out more about how Google uses information from sites or apps that use our services by reviewing the privacy policy available at www.google.com/policies/privacy/partners/.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you sign up for our Web App, we may collect your information to complete that transaction, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about the Online Services. If we wish to use your personal information for a purpose which is not compatible with the purpose for which it was collected for, we will request your consent, unless there is an exception which applies under applicable law, such as those listed in the section below. In all cases, we balance our legal use of your personal information with your interests, rights, and freedoms in accordance with applicable laws and regulations.

Disclosure of Personal Information

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information we collect from you:

• (1) if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our clients or others
• (2) to our authorized service providers, such as our contractors and other third parties we use to support our business;
• (3) to fulfill the purpose for which you provide it;
• (4) to a buyer or other successor in the event of a sale, merger, reorganization or transfer of some or all of our business or assets;
• (5) for any other purpose disclosed by us when you provide the information;
• (6) to comply with any court order, law or legal process, including responding to any government or regulatory request;
• (7) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections; or
• (8) with your consent. We do not sell your personal information or otherwise share personal information with third parties for direct marketing purposes.

Your Choices

You can make the following choices regarding your personal information:

1. Right to Access to Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. 
2. Right to Data Portability. You may have the right to obtain a copy of the personal information that you previously provided.  We will provide this information in a portable format, to the extent technically feasible, readily usable format that allows you to transmit your personal information to another controller without hindrance, where the processing is carried out by automated means. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
3. Right to make Changes to Your Personal Information. We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information, you contact us at the address described below in order to request that your information be modified. Note that we may keep historical information in our backup files as permitted by law.
4. Right to Deletion of Your Personal Information. Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
5. Right to Object to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
6. Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
7. Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can
   stop receiving promotional emails by following the unsubscribe instructions in the e-mails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
8. Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”
9. Revocation Of Consent. If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires
   us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

Please address written requests and questions about your rights to privacyinfo@incentiv.co.

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Note that, as required by law, we will require you to prove your identity.  We may verify your identity by a phone call or email. Depending on your request, we will ask for information such as your name or other account information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

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In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf.  We will require verification that you provided the authorized agent permission to make a request on your behalf.  You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.  If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:

1. A completed notarized statement executed by you and the consumer indicating that you have the authorization to act on the consumer’s behalf.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access and disclosure. The use of, and access to, your personal information by us is restricted to authorized individuals who need to know that information to provide services to you, and who receive training about the importance of protection personal information. We maintain physical, electronic and procedural safeguards to limit access to your nonpublic personal information.  Only authorized individuals access your personal information, and they receive training about the importance of protecting personal information. Our service providers and business partners are also contractually bound to maintain the confidentiality of personal information and may not use the information for any unauthorized purposes.

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Unfortunately, no method of transmission of information via the internet or electronic storage is completely secure. Although we use reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our website or other electronic means. Any electronic transmission of personal information is at your own risk. In the event that we are required by law to inform you of a breach of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

How we retain your personal information

The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use and/or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

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We may anonymize your personal information (so that it can no longer be associated with you) for research, statistical or other business purposes. We may use this aggregated, anonymized, or de-personalized information indefinitely.  We may retain personal information for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. You can request further details of retention periods for different aspects of your personal information by contacting us.

International Data Transfers and EU-U.S. Data Privacy Framework

We are a global business, with our primary location in the US. The personal information (or “personal data”) which we collect from you will be stored in the US and in the European Economic Area (“EEA”), and it may be transferred to a destination outside the EEA or the UK, namely to the US. You acknowledge the transfer to, and storing, or processing outside of the EEA or UK of your personal information as set out in this Privacy Policy.

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Incentiv complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Incentiv has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/

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In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Incentiv commits to resolve DPF Principles-related complaints about our collection and use of personal data. EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, should first contact Incentiv at: privacyinfo@incentiv.co.  If you do not receive timely acknowledgement of your inquiry or complaint, or if we have not addressed your inquiry or complaint, please contact your local data protection authority (DPA) or the UK Information Commissioner’s Office (UK ICO) and we will work with them to resolve the concerns.  In certain circumstances the EU-U.S. DPF Principles provide the right to invoke binding arbitration to resolve complaints not resolved by other means.

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In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Incentiv commits to cooperate and comply respectively with the advice of the panel established by the EU DPAs and the UK ICO with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

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Incentiv is responsible for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf.  Incentiv complies with the EU-U.S. DPF Principles for onward transfers of personal data, including the onward transfer liability provisions.

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The Federal Trade Commission has jurisdiction over Incentiv’s compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  In certain situations, Incentiv may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Other Important Information

• Third-Party Providers. Some applications and services may be embedded within our Site or Web App, or linked from our Site or Web App. These third parties may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use our Site or Web App or navigate away from our Site or Web App. These third parties may also have privacy policies that differ from ours. For example, they may collect personal information about your online activities over time and across different websites, and other online services, and may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third-parties or their privacy practices, and this Privacy Policy does not apply to any third-party website or service you may access through our website. If you have any questions about a third-party provider’s privacy policies or advertising, you should contact the responsible provider directly.
• Non-Personal Information. This Privacy Policy does not restrict our collection, use or disclosure of any aggregated information or information that does not identify, or cannot be reasonably linked to, any individual.
• Accessibility.  If you have a disability and require an alternative format to this Privacy Policy, please email us at: privacyinfo@incentiv.co so that we may provide you with a more suitable format.
• Changes to Our Privacy Notice. We will post any changes we make to this Privacy Notice on our website. If we make material changes to how we treat personal information we collect from you, we may notify you by email or through a notice on our website homepage. The date this Privacy Policy was last revised is identified above. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Privacy Policy on our website to check for any changes.

GDPR Transparency Statement

If you are dissatisfied with Incentiv’s transparency regarding data protection and data privacy, you have the right to contact to your local data protection authority.  You can find the list at:

https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm