Overview
Lincé Consulting, LLC is committed to protecting the privacy of all information we collect from: clients, research participants and visitors to our website (www.LinceConsulting.com). This policy applies to all personal information (“PI”) that we collect or use in conducting our business and covers all client information and research participant data stored on the Lincé Consulting, LLC network. Access to PI is restricted; those authorized to access PI data must adhere to the terms set forth in this policy.

About Lincé Consulting, LLC Lincé Consulting, LLC (“Lincé”) is a consulting organization focused on delivering top quality, responsive Regulatory, Clinical and Quality consulting services based in the US and providing services to clients worldwide.

EU – U.S. Data Privacy Framework and Swiss – U.S. Data Privacy Framework
Lincé Consulting, LLC adheres to the EU‐US Data Privacy Framework (DPF) and the Swiss‐US Data Privacy Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union member countries and Switzerland. Lincé Consulting, LLC has self‐attested to the Department of Commerce that it adheres to the Data Privacy Framework Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in 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, and to view the online Data Privacy Framework registry page, please visit https://www.dataprivacyframework.gov

Lincé Consulting, LLC is responsible for the processing of personal information it receives, under each Data Privacy Framework, and any subsequent transfers to third parties acting as an agent on behalf of Lincé Consulting, LLC. Data transfers, conducted for any reason, are for specified research purposes only. Lincé Consulting, LLC adheres to the Data Privacy Framework Principles for all onward transfers of PI from the EU and Switzerland, including the onward transfer liability provisions. Vendors or third parties working with Lincé Consulting, LLC must adhere to Lincé Consulting, LLC guidelines for data security and confidentiality. Any third parties acting as controllers must maintain, at a minimum, the level of data security and privacy protection as specified by the Data Privacy Framework.

In adhering to the EU‐US and Swiss‐US Data Privacy Framework Principles, Lincé Consulting, LLC commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Lincé Consulting, LLC by email at privacy@LinceConsulting.com or by telephone at (650) 759-6186; all inquiries should be directed to the Privacy Officer.

Lincé Consulting, LLC has further committed to refer unresolved privacy complaints under the EU‐US and Swiss‐US Data Privacy Framework Principles to The Insights Association Data Privacy Framework Services Program, a non‐profit alternative dispute resolution provider located in the United States and operated by the Insights Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.insightsassociation.org/Resources/Data‐Privacy‐Framework/Information‐for‐EU‐Swiss‐Citizens‐to‐file‐a‐complaint for more information and to file a complaint. These dispute resolution services are provided at no cost to you.

In some limited circumstances, individuals may invoke binding arbitration before the International Centre for Dispute Resolution / American Arbitration Association (ICDR/AAA).

With respect to personal information received or transferred pursuant to the Data Privacy Frameworks, Lincé Consulting, LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Information We Collect
From Research Participants: We conduct both qualitative and quantitative market research. The qualitative work involves small numbers or groups of people; the quantitative work can include surveys of larger numbers of participants. Only a small subset of the data we collect about you, as a research participant, is personal information; this is information that you voluntarily disclose to us in connection with our research studies. Data collected as part of our studies may include respondent demographic data and respondent‐supplied opinions on products or brands. Your participation in our research studies is voluntary; you always have the option to exit the research (“opt out”) after agreeing to participate. In each survey, the opt‐out feature is clearly identified.

You are entitled to request a copy of your personal information that we hold. You can also edit your personal information, including your address and contact details at any time. In addition, you are entitled to request the deletion of your personal information that we hold; we review such requests on a case‐by‐case basis. For any information access request (including deletion), please provide as much information as possible about the nature of your contact with Lincé Consulting, LLC. Any changes requested can take up to 30 days before they take effect. All information access requests should be directed by email to the Privacy Officer at privacy@Lincé Consulting.com.

If the research study includes an incentive for participation, we may ask for your name and a mailing address. You are never under any obligation to provide this information to participate in the survey but if you do not provide it, you may not be able to participate in the distribution of any offered incentive. Our legal basis for collection and processing of respondent‐supplied personal information is consent; we do not collect personal information without the affirmative consent of the research participant. Consent can be withdrawn at any time.

We may obtain information about you from our clients, third party vendors, or partners for use in connection with research studies. Depending upon applicable law this information may be defined as PI. In those cases, our legal basis for the processing of the information is our legitimate interest to perform our obligations under our contract with the client commissioning the research study in question.

From Client Organizations: If you are a client or work for a client, we will collect various contact and business information about you in conducting business with you or your employer. In those cases, our legal basis for the collection and processing of the information is our legitimate interest to perform our obligations under our contract with you or the company for which you work.

From the Lincé Consulting, LLC Web Site: When you visit the Lincé Consulting, LLC website, we automatically gather certain information that may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site. Lincé Consulting, LLC and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base in the aggregate. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

Lincé Consulting, LLC uses Google Analytics to measure traffic on its website and Google’s ReCaptcha for spam detection and prevention. Submitting a form on a website that uses ReCaptcha requires acceptance of Google’s terms of service and privacy policy, which you can review at https://support.google.com/analytics/answer/6004245?hl=en . If you would like to opt out of tracking by Google Analytics, you can visit the Google Analytics opt‐out page at
https://support.google.com/analytics/answer/181881?hl=en .

Children: We do not contact children under the age of 18 without consent from a parent, guardian, or an accredited Institutional Review Board.

Lincé Consulting, LLC utilizes partners, affiliates, subcontractors and third‐party data collection agencies to collect data for research projects that we conduct on a global basis. For studies (qualitative or quantitative) in the United States with small numbers of respondents, Lincé Consulting, LLC may also collect data directly (without the assistance of affiliates, subcontractors or third‐parties) using cloud‐based survey platforms to which Lincé Consulting, LLC subscribes. Any data we collect and process in connection with our business activity may be transferred between or among two or more countries (including from the EU to the US and Switzerland to the US), between Lincé Consulting, LLC and a client or other third party described above. In all cases, we will take appropriate measures to ensure that the recipient protects any PI so transferred adequately in accordance with this privacy policy. These measures include, in the case of transfers from the EU and Switzerland to the US, adherence to the Privacy Principles described in the EU‐US and Swiss‐US Data Privacy Frameworks (see details above).

It is understood that transmission of information across the internet is not completely secure. Although we will do our best to protect your personal information (e.g., data encryption), we cannot guarantee the security of your information transmitted to our site and therefore any transmission is at your own risk. Once we have received your information, we will use strict procedures and security measures to protect your information from unauthorized access or disclosure.

Use of Information We Collect
Depending on how we obtain your personal information (as described above), we may either be considered a “controller” or a “processor” under applicable law as to that data. If we are the processor, we will process the data in accordance with the instructions provided to us by the controller of that data.
From Research Participants: For any research study, Lincé Consulting, LLC collects data (either directly in the research or in connection with the same) for research purposes only and our use of that information is limited to that purpose. Research participant data and responses are not used by any entity to aid sales activities. In many cases, research participant data and responses (which is typically anonymized) is shared with the client commissioning the study pursuant to our contract with that client.

From Client Organizations: Information that Lincé Consulting, LLC receives from client organizations is used only to fulfill our obligations to these clients. All client information is secured to prevent disclosure and use by any third‐parties.

From the Lincé Consulting, LLC Web Site: If you visit the Lincé Consulting, LLC website and provide PI to Lincé Consulting, LLC through an inquiry about our services, Lincé Consulting, LLC will use that PI only to contact you about services provided by Lincé Consulting, LLC. We will also use data collected from visitors to the Lincé Consulting, LLC website to maintain the site, improve the site and/or improve the services we offer.

Disclosures
In some cases, Lincé Consulting, LLC may need to share personal information with third parties for ancillary services in support of a research project. In these cases, we require the third party to follow all of the same privacy protection regulations as followed by Lincé Consulting, LLC does not rent, sell or give personal data to any third party for the purpose of directly marketing any products or services. Under certain circumstances, we may be required to release personal data in response to a legal request from public authorities including to meet national security or law enforcement requirements.

Opt‐Out Policy
If you wish to be removed from Lincé Consulting, LLC email or phone contact lists, please contact the Lincé Consulting, LLC Privacy Officer at privacy@LinceConsulting.com .

Changes in Our Privacy Policy
Lincé Consulting, LLC may update this Privacy Policy in the future. Lincé Consulting, LLC reserves the right to update this Privacy Policy and communicating that change simply by posting the updated policy and without any express notice to you. Lincé Consulting, LLC encourages you to check this Privacy Policy from time to time to ensure that you have reviewed and are aware of any updates.