PRIVACY POLICY

Infinata, Inc. (“we”, “us”, “our” or “Infinata”) 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.

This Privacy Policy applies to all Personal Information gathered for and on behalf of Infinata through any source the various Infinata sites that link or refer to this Privacy Policy (such as any website operated by or on behalf of Infinata, social media pages and HTML-formatted e-mail messages) together with any and all offline sources including sales and marketing activities (collectively, the “Sources”). By using the Sources, you consent to the data collection and use practices described in this Privacy Policy. If you have questions about this Privacy Policy or the protection of your information, please contact us at accounting@infinata.com.  This page states the Privacy Policy applicable to the infinata.com website (the “Website”) as of December 1, 2016.  Please read this page carefully.  As used herein, the words “user,” “you” and “your” mean users of the Website.

Collection and use of non-personal information

If you visit the Website, we do not collect any personally identifiable information about you (such as your name, address, phone number or email address) unless you provide it, as described under “Collection of personal information” below. We do, however, collect non-personally-identifiable (anonymous) information about you, such as the server your computer is logged into or your browser type. Other examples of non-personally-identifiable information include: Your IP address (a unique number that is automatically assigned to your computer whenever you are surfing the Web; many Web servers automatically identify your computer by its IP address). Your domain type (i.e., .com, .net, .edu, etc.).  Standard information included with every communication sent on the Internet, such as browser type, operating system, browser language, service provider, and local time. Infinata collects data from the Web logs of its servers -- the computers that "serve up" Web pages -- delivering the Infinata content.  This includes information about what you view and, along with information gathered from our other users, we create "aggregate data" reports that we may disclose to third parties, including our clients with whom we have entered into an agreement to provide such information. We may also study aggregate data in order to enhance our existing services or develop new services. We will not disclose any personal information to a third party without your express prior written authorization. We can and will use IP addresses to identify a user when we feel it is necessary to enforce compliance with our terms of use or to protect our service, site, customers, or others.

Use of cookies and web beacons

Infinata uses cookies, which are small text files placed on your computer's hard drive, and web beacons (also known as pixel tags), which are electronic images embedded into a web page, on the Website.  Cookies and web beacons are used for record keeping, to track your movements when you visit the Website and to help us determine what type of information to present to you. The use of cookies and web beacons is an industry standard - you'll find them used at most Web sites. Our cookies and web beacons do not contain any personally identifiable information about you, and do not damage or alter your system files in any way. The first time you visit the Website, Infinata assigns you a unique, anonymous ID, which is stored in the cookie on your computer.

Collection of personal information

You must provide personal information such as your name and e-mail address in order to use certain services (“Services”) of the Website.  We will not collect any information from you except that necessary for the provision of the Services.

We will not disclose your e-mail address or other information which you provide as part of subscribing to the services to any third parties. The Services may include e-mails (at your request) of updates or alerts using criteria specified by you. We may also occasionally inform you of new services or products which become available from us from time to time.

Who is collecting your information

Your information is being collected solely by Infinata. See the discussion under "With whom your information may be shared" below concerning the circumstances under which certain of your information may be disclosed to third parties.

How we collect information 

Infinata 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. Such data may include information such as your name, title, contact information, and biographic information.
  • 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 Infinata 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 Infinata 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.

Infinata’s use of Automated Interactions may change over time as technology evolves. The descriptions above are designed to provide you with some detail about Infinata's current approach to information collected from Automated Interactions.

Infinata’s Operations

We use Personal Information and other information collected to (a) allow you to participate in the public areas and/or other features of Infinata’s websites; (b) respond to your questions or other requests; (c) contact you regarding your use of the Sources, for informational purposes related to the Sources or, in our discretion, regarding changes to this Privacy Policy or related policies; (d) improve the Sources and for internal business purposes; (e) tailor your experience of the Sources and/or otherwise customize what you see when you use the Sources; and (f) otherwise to maintain, operate and administer the Sources and for other purposes disclosed at the time you provide the information.

With whom your information may be shared

We share some kinds of Personal Information as part of our subscription products.  We package certain “Publicly Available Data / Data from Third Parties” (as discussed above) into subscription products which are sold to clients.  Infinata’s clients are generally pharmaceutical companies, CROs, asset managers.  These clients generally seek such information for use in business-to-business settings only.  Your information would not be used in any manner that is inconsistent with this Privacy Policy without your prior permission.

While we cannot guarantee that 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 individuals received pursuant to the EU-US Privacy Shield.

Sharing non-identifiable information

Information we collect that is not Personal Information or Personal Information that has been converted to information which cannot be used to identify you is not limited in any way by this Privacy Policy and can be used and disclosed by us in any manner and for any purpose.

Retention of information

Any information we collect may be retained for an indeterminate period of time: as needed to provide products or services; as needed for the purposes outlined in this Privacy Policy; as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; or to the extent permitted by law.

Confidentiality and security

Infinata has implemented generally accepted standards of technology security in order to protect information from loss, misuse and unauthorized access, disclosure, alteration or destruction. Only employees of Infinata have access to the information we collect, and these employees are made aware of and required to comply with our Privacy Policy.

Links to other sites

The Website may provide links to an external Web site. When you click on such a link, you will leave Infinata. The Privacy Policy of the external Web site will then be in effect, not Infinata’s. Infinata does not control or makes an endorsement of any kind regarding the external site or its Privacy Policy. Infinata’s policy does not extend to anything that is inherent in the operation of the Internet, and therefore beyond Infinata’s control, and is not to be applied in any manner contrary to applicable law or governmental regulation. We do not control cookies from the other sites that you may link to from Infinata.

Children

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 accounting@infinata.com.

Changes to this Privacy Policy

All versions of this Privacy Policy are dated with the effective date (the date on which the policy was posted to Infinata’s website). Infinata will only use the information we learn about you in the manner described in the Privacy Policy in effect when the information was collected from you. However, we reserve the right to change the terms of this Privacy Policy at any time by posting revisions to our site.

Changes in corporate structure

If Infinata (or a business unit or asset of Infinata) is sold, merged or otherwise transferred to another entity, the personal information you have provided at this site may be transferred as part of that transaction. However, we will take steps to assure that any personal information is used in a manner consistent with the Infinata Privacy Policy under which it was collected.

Effect of legal obligations upon this Privacy Policy

Infinata may disclose user information in special cases when we have reason to believe that disclosing this information is necessary to comply with law, to cooperate with or seek assistance from law enforcement, to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) Infinata’s rights or property, other Infinata users, or anyone else that could be harmed by such activities. Infinata may disclose user information when we believe in good faith that the law requires it. Infinata may release information if, in our judgment the release may be necessary to prevent the death or serious injury of an individual.

Access, Correction, and Updates

You may request to review, correct, update, delete, or otherwise modify any of your Personal Information, or object to the use, disclosure or processing of such Personal Information by us. To do so, please contact us at:

accounting@infinata.com

or write to us at:

Infinata, Inc.
Attn: Erin Bahouth
41 Farnsworth St
Boston, MA 02210

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.

Cross Border Transfers and EU-US Privacy Shield

Infinata is a global corporation and has developed global data practices designed to assure your Personal Information is appropriately protected. Please note that your Personal Information may be transferred, accessed and stored globally as necessary for the uses stated above in accordance with this Privacy Policy. By using the Sources, you consent to the transfer of information to countries outside of your country of residence, which may have different data protection rules than those of your country.

Infinata complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  Infinata has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  Infinata further certifies that it adheres to the Supplemental Principles, including Supplemental Principal 15: Public Record and Publically Available Information. You may find Infinata’s certification to the Privacy Shield at https://www.privacyshield.gov/list.  If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, Infinata commits to resolve complaints about our collection or use of your Personal Information.  European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Infinata at:

accounting@infinata.com

or write to us at:

Infinata, Inc.
Attn: Erin Bahouth
41 Farnsworth St
Boston, MA 02210

Infinata has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit JAMS at https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint.  The services of JAMS are provided at no cost to you.

Related to its participation in the Privacy Shield program, Infinata is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).  Further, you may seek the possibility, under certain circumstances, for binding arbitration to resolve your complaint.

Effect of Privacy Policy

This Privacy Policy is not intended to and does not create any contractual or legal rights in or on behalf of any party. As noted above, we may revise this Privacy Policy from time to time in our sole discretion.

Questions

If you have any questions about this Privacy Policy, please contact us at accounting@infinata.com.