Inizio Group Limited
and each of its subsidiaries
(together, the Inizio Group)
Data Privacy Framework Policy
This Data Privacy Framework Policy (“Policy”) describes how Inizio group and its subsidiaries and affiliates in the United States (“US”) (“Company,” “we,” or “us”) collect, use, and disclose certain personally identifiable information that we receive in the US from the European Economic Area (“EEA”), Switzerland and United Kingdom (“UK”). We recognize that the EEA, Switzerland and UK has established strict protections regarding the handling of EEA, Switzerland and UK Personal Data, including requirements to provide adequate protection for EEA, Switzerland and UK Personal Data transferred outside of the EEA, Switzerland and UK.
Inizio will process data from the EEA, Switzerland and UK in compliance with the Data Privacy Framework principles (which include Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability). More information on Inizio’s Data Privacy Framework certification is included in this document.
This Policy applies to Ulysses US Newco LLC element of the Inizio group, and all its US affiliated entities (See appendix A) that receive personal information from the EU, Switzerland and UK who commit to comply with the EU-U.S Data Privacy Framework Principles and/or Swiss US Data Privacy Framework Principles and UK Extension as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EEA, Switzerland and UK to the U.S.
Ulysses US Newco LLC and all its US affiliated entities have self-certified to the U.S. Department of Commerce that they adhere to the Data Privacy framework Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement, and liability for onward transfer to third parties, the Data Privacy Framework Supplemental Principles and the Swiss-U.S. Data Privacy Framework principles. If there is any conflict between the terms of this Privacy Policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. To learn more about the Data Privacy Framework program visit https://www.dataprivacyframework.gov/s/ and to view Inizio’s certifications, please visit https://www.dataprivacyframework.gov/s/participant-search
This Policy supplements our Website Privacy Policy located at https://www.inizio.health/privacy-policy/, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website Privacy Policy.
We comply with the Data Privacy Framework Principles for all onward transfers of personal data from the EEA, Switzerland and UK, including the onward transfer liability provisions.
Personal Data Collection and Use
Our Website Privacy Notice located at https://www.inizio.health/privacy-policy/ describes the categories of EEA, Swiss and UK Personal Data that we may receive in the US as well as the purposes for which we use that Personal Data. We process EEA, Swiss and UK Personal Data for the following purposes: to receive and process information about existing and potential corporate customers, clients, suppliers, business partners, job applicants and employees. We will only process EEA, Swiss and UK Personal Data in ways that are compatible with the purpose that we collected it for, or for purposes the individual later authorizes. Before we use your EEA, Swiss and UK Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. We maintain reasonable procedures to help ensure that EEA, Swiss and UK Personal Data is reliable for its intended use, accurate, complete, and current.
Data Transfers to Third Parties
Third-Party Agents or Service Providers. We may transfer EEA, Swiss and UK Personal Data to our third-party agents or service providers who perform functions on our behalf as described in our Website Privacy Notice. Where required by the Data Privacy framework, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Data Privacy framework requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process EEA, Swiss and UK Personal Data in accordance with our Data Privacy Framework obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of EEA, Swiss and UK Personal Data that we transfer to them.
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your EEA, Swiss or UK Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Security
We maintain reasonable and appropriate security measures to protect EEA, Swiss and UK Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Data Privacy Framework.
Our employees are trained in-line with and required to adhere to the principles of the applicable Data Protection laws and Data Privacy Framework Principles in their country of employment.
Access Rights
You may have the right to access the EEA, Swiss or UK Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Data Privacy Framework. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EEA, Swiss or UK Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Choice/Opt-Out
Should you no longer wish to receive information or future communications about our relevant services, please contact us using one of the following options. You may send your request via email stating your desire to opt out of further communications to [email protected] or alternatively you may write to us at:
Data Protection Officer
Inizio
8th Floor
Holborn Gate
26 Southampton Buildings
London, WC2A 1AN
We also provide an opt-out option with all marketing email communications by either clicking the unsubscribe link at the bottom of the email or replying to the email stating your request to opt-out of further communications. If we intend to use personally identifiable information in a manner different from that stated within this Privacy Policy or as otherwise previously notified, we will notify all affected users; users will be able to opt out of any new use of their personal information.
Contact Us, Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your EEA, Swiss or UK Personal Data to us at: [email protected] or alternatively you can write to us at:
Data Protection Officer
Inizio
8th Floor
Holborn Gate
26 Southampton Buildings
London, WC2A 1AN
In compliance with data privacy laws and the Data Privacy Framework Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information.
We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EEA, Swiss and UK Personal Data within 45 days of receiving your complaint.
We have further committed to refer unresolved privacy complaints under the Data Privacy framework to an independent dispute resolution mechanism, the International Centre for Dispute Resolution, the international division of the American Arbitration Association (ICDR/AAA). If you do not receive timely acknowledgement of your privacy complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit the ICDR/AAA web site at https://go.adr.org/dpf_irm.htmlfor more information or to file a complaint. EU, Swiss and UK complainants may invoke binding arbitration under the Data Privacy Framework Principles if a complaint has not been resolved by Inizio or by other recourse and enforcement mechanisms. Inizio’s US businesses are also subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Inizio has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) the Swiss Federal Data Protection and Information Commissioner (FDPIC) and UK Information Commissioners Office (“ICO”) with regard to unresolved Data Privacy Framework complaints concerning human resources data transferred from the EU, Switzerland and UK in the context of the employment relationship. If you have a complaint relating to Human Resources data transferred from Inizio’s EEA, Swiss or UK businesses that cannot be resolved by Inizio’s internal dispute resolution process, you may refer your complaint to the Data Protection Panel secretariat established by the EU Data Protection Authorities (DPA) at the following address: European Commission, Directorate General Justice, Data Protection Panel, B-1049 Brussels, Belgium. Telephone: (32-2) 299.11.11; Fax (32-2) 298.80.94. https://ec.europa.eu/info/departments/justice-and-consumers_en#contact
Binding Arbitration You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps:
(1) raised your compliant directly with us and provided us the opportunity to resolve the issue;
(2) made use of the independent dispute resolution mechanism identified above; and
(3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Data Privacy Framework: Annex I (Binding Arbitration).
Contact Us
If you have any questions about this Policy or would like to request access to your EEA, Swiss or UK Personal Data, please contact us as follows: [email protected] or you can write to us at:
Data Protection Officer
8th Floor
Holborn Gate
26 Southampton Buildings
London, WC2A 1AN
Changes To This Policy
We reserve the right to amend this Policy from time to time consistent with the Data Privacy Framework requirements.
Effective Date: 19.3.2024
Appendix A
US affiliated entities (Covered entities)
| AH Services, Inc |
| Ashfield Health, LLC |
| Ashfield Healthcare LLC |
| Ashfield Market Access LLC |
| Ashfield Meetings and Events Inc |
| Cormis Partnership LLC |
| Creativ-Ceutical USA Inc |
| Dutko Global LLC |
| Dutko Worldwide, LLC |
| Evoke Canale LLC |
| Evoke Create, LLC |
| Evoke Giant LLC |
| Evolution Road, LLC |
| Grayling Communications Inc |
| HH Medical Inc |
| Huntsworth Group LLC |
| Inizio Evoke Comms LLC |
| Huntsworth Health North America LLC |
| Inizio Evoke Drive, LLC |
| Inizio Evoke Media, LLC |
| Inizio Evoke North America LLC |
| Inizio Evoke Transformation LLC |
| Inizio Services North America LLC |
| Institute for Medical and Nursing Education, Inc |
| Medistrava LLC |
| Nuvera LLC |
| Propensity4 Smart Data, LLC |
| Putnam Associates, LLC. |
| SmartAnalyst Inc |
| STEM Healthcare US Inc |
| The Creative Engagement Group Inc. |
| The Moment Content Company, LLC |
| The Nucleus Group Holdings, Inc |
| The Research Partnership Inc. |
| Vynamic LLC |
