Privacy Policy

NARRATIVE HEALTH LLC PRIVACY POLICY
This Notice was last updated on: Oct 3^rd 2024

At Narrative Health LLC (“Narrative Health”) we take your privacy very seriously. Our Privacy Notice sets out how we use your personal data and your rights in relation to the personal data we hold.

This Privacy Notice (“Notice) applies to Narrative Health LLC (“Narrative Health”). This Notice adopts the fundamental principles of the EU’s General Data Protection Regulation (“GDPR”) as the minimum standard to which Narrative Health, its employees, and suppliers adhere. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

California residents who participate in our research  studies are directed to review our CCPA Privacy Statement which is located at the end of this Notice.

Narrative Health complies with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework and the Swiss-U.S. Data Privacy Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union, the United Kingdom and Switzerland to the United States, respectively.

Narrative Health has certified to the Department of Commerce that it adheres to the DPF Principles for data protection: notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability for personal data submitted by data subjects in the European Union, United Kingdom and Switzerland and our Data Privacy Framework self-certification is available here.

If there is any conflict between the terms in this Notice and the DPF Principles, the DPF Principles shall govern.

Narrative Health acknowledges that as a participant in the DPF Framework it is under the enforcement authority of the Federal Trade Commission.

To learn more about the Data Privacy Framework program, please visit https://www.dataprivacyframework.gov/s/

Narrative Health is not relying on the DPF as a legal mechanism for cross-border transfers of personal data.  We may process personal data relating to individuals in the United Kingdom, Switzerland and in the EU via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses or via other legal bases as outlined in the HOW WILL WE USE YOUR DATA? section of this Notice.

In compliance with the EU-U.S. DPF, Narrative Health commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF

HOW DO WE COLLECT YOUR DATA?

We may collect and process the following data about you:

• Information that you provide by filling in forms on our site www.narrative-health.com. This includes information provided at the time of making any general inquiry or when applying for a job with Narrative Health. The information collected includes name, email, phone number, IP address and any information provided as part of your inquiry or job application, the latter including resumes/CVs and any information provided to us on your application form and associated emails.
• Data from our clients and prospective clients when they register with our website; request information from us; purchase our services and in compliance with our contractual obligations including managing transactions, reporting, invoices and other operations related to providing and receiving services; as part of a market research project (e.g. observer forms) or otherwise communicate with us.
• We collect data from our research participants as part of our market research studies via a number of media, including but not limited to, consent forms, audio and video files/recording, screeners and questionnaires, online communities, publicly available sources, mobile applications, eye tracking/facial coding, and adverse event reporting forms. If you are a research participant, we may also be lawfully passed your data by our clients , the research sponsor, for the purposes of recruitment for an applicable study (e.g., market research, advisory boards or other project).

WHAT DATA DO WE COLLECT?

 The following is typical of the personal data collected, held, and processed by Narrative Health:

• Name (first, surname)
• Contact details (typically, phone number, fax number, postal and email address)
• Role profile (job title, job description, years of service, academic qualifications and training details)

Narrative Health may occasionally collect, hold, and process the following personal data; this use will be dependent on the methodology, topic, and purpose of the market research study, as well as the types of research participants being interviewed:

• Date of Birth
• IP address
• Image and voice as part of the audio and video recording or research
• Family, Lifestyle and Social circumstances related information (for example, current marriage and partnerships, marital history and details of family and other household members, housing, habits and travel/leisure activities)
• Work related information
• Income details
• Details of professional activities and interests
• Goods or services provided and related information

We may also collect sensitive/special category data, with your consent, for research purposes including:

• Information on health and medical conditions (depending on the nature of the research project we are conducting)
• Information on racial or ethnic origin
• Information concerning sexual life or orientation (as it related to a medical condition discussed as part of a research project)
• Biometric data (eye tracking, facial coding)

HOW WILL WE USE YOUR DATA?

Narrative Health uses the personal data we collect for the following purposes:

• In the execution of our market research studies. For example ,we use information held about you to respond to you during the interview / recruitment process and this can be shared with those who are contacting you to schedule, organize an interview or conduct the research interview or to follow up for further queries.
• To respond to your inquiries, including those received via our website contact form.
• To contact our clients and prospective clients regarding our services and to provide any commissioned services.
• In employment relationships, personal data can be processed if needed to initiate, carry out and terminate the employment agreement. When initiating an employment relationship, the applicant’s personal data will be processed. If the candidate is rejected his/her data will be deleted unless the applicant has agreed to remain on file for a future selection process.
• As otherwise necessary to comply with our legal obligations.

Personal data will be processed and collected lawfully, fairly and in a transparent manner. Narrative Health will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized.  We will take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete, and current. We use reasonable efforts to maintain the accuracy and integrity of personal data and to update it as appropriate.

Our legal bases for the processing of your personal data may fall into one of the following categories:

Consent

When we rely on consent for the processing of personal data, we will inform you of this fact and gain your consent for how your data will be used and handled. If we collect personal data as part of the research project we are conducting, we will obtain your consent at the time of the project as per our industry association guidelines and codes of conduct.  If sensitive/special category data is included in the collection, we will collect your explicit consent for its processing.

You are free to withdraw or modify your consent at any time. Simply email us at team@narrative-health.com or contact us by phone +1-917-702-0241.

Legitimate interest

We also process personal data to pursue the legitimate business interests of Narrative Health and our clients. Our ‘legitimate interests’ include providing healthcare market research services and ensuring that Narrative Health is run in a professional and sustainable manner in accordance with relevant ethical, legal and regulatory duties and requirements.  We ensure that such processing is in balance with the rights and expectations of the data subjects whose personal data will be processed under this legal basis.

Contract

We may also process personal data if the processing is necessary for a contract we have with the data subject.

TO WHOM WILL WE DISCLOSE YOUR PERSONAL DATA?

We will not sell, share, transfer, or rent any Personal data to any third parties in ways different from what is disclosed in this Notice. Except as otherwise outlined in this Notice, we disclose personal data only to third parties who reasonably need to know such data. Such recipients must agree to abide by confidentiality obligations.

Narrative Health recognizes its potential liability in cases of onward transfer to third parties and will ensure that any third party to whom we disclose personal data provides the same level of privacy protection as is required by the applicable data protection regulations and agrees in writing to provide an adequate level of privacy protection.

We may disclose your personal data to:

• Any staff member of Narrative Health where necessary to allow that staff member to respond to any enquiry you make or as part of the market research process.
• Other employees, agents, and contractors (e.g., suppliers who process data on our behalf, such as our accountants, lawyers, employment recruitment agencies and research suppliers including transcription agencies and research platform providers).
• Pharmaceutical and Medical Device manufacturers that sponsor our research projects if an adverse event, product complaint or safety issue is raised within the interview. In this situation, and if applicable based on your home country, you will be asked if you give your consent for your details to be passed on to our client for this purpose. We may also, with your consent, pass on audio or video footage to help illustrate our findings and help our clients better understand their business issues.
• External auditors, tax authorities and inspectors (such as HMRC, auditors).

In addition, we may disclose your personal data to:

• Allow us to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
• Investigate or prevent fraud, or to take action regarding illegal activities, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
• Transfer information about you if Narrative Health is acquired by or merged with another company. In this event, Narrative Health will notify you before information about you is transferred and becomes subject to a different Notice.

HOW DO WE STORE YOUR DATA?

The data that we collect from you is stored securely on encrypted servers. It may be transferred to and stored at a destination outside your home country, and it may also be processed by our team operating outside of the United States who work with us in the United Kingdom and Europe or via our suppliers.

By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Notice. Despite these precautions, no data security safeguards guarantee 100% security all of the time.

FOR HOW LONG WILL WE RETAIN YOUR PERSONAL DATA?

Your personal data will not be kept for longer than is required for the purpose of processing or is required per applicable law.

Information related to our market research activities, including adverse reporting data and its source materials, may be held up to 10 years or per the guidelines dictated by the contractual terms of our clients if they are different from our internal retention guidelines. We retain personal data such as research participant contact details only for as long as is required per the related processing.

For more information on our retention guidelines, you can contact us at team@narrative-health.com

INDEPENDENT RECOURSE MECHANISM

We commit to resolving individuals’ complaints related to our privacy practices or our collection, or use, or disclosure of personal data.  An individual may file a privacy complaint by connecting with us via email, phone or postal mail as noted in the HOW TO CONTACT US section of this Notice.

Further, individuals with questions or concerns about the use or disclosure of their Personal Data should contact us as outlined in the HOW TO CONTACT US section of this Notice

If an EU or Swiss individual’s complaint cannot be satisfied through our internal complaint process, the individual may bring a complaint before 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. The INSIGHTS ASSOCIATION DPF SERVICES PROGRAM is designed to handle eligible complaints brought by EU, UK and Swiss citizens about DPF Principles.  If you have any complaints regarding our compliance with the DPF you should first contact us (as provided above).

If contacting us does not resolve your complaint or you do not receive timely acknowledgement of your complaint, please visit the INSIGHTS ASSOCIATION DPF SERIVCES PROGRAM website at https://www.insightsassociation.org/Resources/Data-Privacy-Framework for more information and to file a complaint.  We will cooperate with the independent dispute resolution mechanism to resolve any complaint that is not resolved through our internal processes.  Please note that if an individual’s complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a DPF Panel.

CHANGES TO OUR PRIVACY NOTICE

Any changes we may make to this Notice will be posted on this page and date stamped. We will notify you if we make changes that materially affect the way we handle personal data previously collected, and we will allow you to choose whether your personal data may be used in any materially different manner. If there is anything you are no longer happy with, please feel free to access your rights as set out above, but by continuing to allow us to hold your information you are accepting any changes made to this Notice.

HOW TO CONTACT US

Questions, comments, and requests regarding this Notice should be addressed to team@narrative-health.com

Alternatively, you may call us at: +1-917-702-0241

Or write to us at:

Narrative Health LLC
188 Grand Street, 2nd & 3rd Floor #39
New York, NY 10013
United States

Attn: Avanti Ananthram, Managing Director

United Kingdom

Our UK entity, Narrative Health Ltd, is registered with the Information Commissioner’s Office in the United Kingdom as a Data Controller in accordance with the provisions of the Data Protection Act 2018. Further details of the registration are available at www.ico.org.uk/.

Registered company name: Narrative Health Ltd

Registered company 9221091

20-22 Wenlock Road, London, N1 7GU, United Kingdom

+44 (0) 203 397 9900

EU Data Protection Representative:

Our data protection representative for the European Union is:

JAVIER RODRIGUEZ

Address:

10 Calle Siete Picos,
Madrid, 28002
Spain

Email: privacy@narrative-health.com

Individuals have the right to access their personal data.

WHAT IS A COOKIE?

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device.

You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu.

For a video about cookies visit www.google.co.uk/goodtoknow/data-on-the-web/cookies.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience.

COOKIES WE USE ON THIS WEBSITE

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

FOR CALIFORNIA RESIDENTS

This PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Notice of Narrative Health LLC (“Narrative Health”).  We adopt this statement to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this statement.

Information which we collect

You can review the types of Personal Information which we collect in our Privacy Notice which precedes this statement, as well as in the chart below.

Use of your Personal Information

Narrative Health uses Personal Information that it collects in its market research activities for the following business purposes, without limitation:

• (1) maintaining and supporting our products, delivering, and providing the requested products/services, and complying with our contractual obligations related thereto (including managing transactions, reporting, invoices and other operations related to providing/receiving services);
• (2) satisfying governmental reporting, tax, and other requirements
• (3) storing and processing data, including Personal Information, in computer databases and servers located in the United States, UK;
• (4) verifying identity;
• (5) as requested by you;
• (6) for other business-related purposes permitted or required under applicable local law and regulation; and
• (7) as otherwise required by law.

Disclosure of  Personal Information for a Business Purpose

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

We disclose your Personal Information for a business purpose to the following categories of third parties:

• Our affiliates and subsidiaries
• Our clients or their agents
• Service Providers and consultants
• Professional services organizations, such as auditors and law firms
• Our business partners
• Government entities
• Operating systems and platforms

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:

• Category A: Identifiers.
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
• Category C: Protected classification characteristics under California or federal law.
• Category E: Biometric information.
• Category F: Internet or other similar network activity.
• Category H: Sensory data.
• Category I: Professional or employment-related information.

Your Rights and Choices

Pursuant to the CCPA and subject to certain exceptions and limitations, California residents may contact us to exercise their rights with respect to certain Personal Information that we hold about them.

To the extent these rights may apply to you, they are described below.

Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that we provide you with details about the Personal Information we collect, use, disclose and sell.

You may contact us at by email at to team@narrative-health.com, via phone at +1-917-702-0241 or via postal mail at Narrative Health LLC, 188 Grand Street, 2nd & 3rd Floor #39, New York, NY 10013, Attn: Avanti Ananthram, Managing Director

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your Personal Information.

As part of this process, we may ask to verify your identity. Your request must

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.  Making a verifiable request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable request to verify your identity or authority to make the request.

In connection with this request, you are entitled to receive the following

• The categories of your Personal Information that we have collected in the preceding 12 months
• The categories of sources from which that Personal Information was collected
• The business/commercial purpose for the collection or selling
• The categories of third parties with whom we share Personal Information
• The specific pieces of Personal Information we has collected about you (subject to some exceptions)

Because we have disclosed or sold (as those words are defined in the CCPA) Personal Information to third parties in the last 12 months, you are also entitled to receive:

• The categories of Personal Information that we have disclosed or sold for a business purpose in the past 12 months and the parties to whom that information was sold or disclosed.

Right to Request Deletion of Personal Information

You have the right to request deletion of the Personal Information we have collected about you (subject to some exceptions).  You can submit your request as described above, and we reserve the right to conduct the verification described above.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the Personal Information, provide a service that you requested, or take actions reasonably anticipated within the context of our ongoing business relationship with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you for exercising any of your CCPA rights.  Unless permitted by the CCPA, we will not

• Deny you use of our services.
• Provide you a different level or quality of services.

Right to Opt-Out of Sale of Personal Information

The term “sell” in the CCPA is defined broadly as “…selling, renting, releasing, disclosing, disseminating, making available, transferring… a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.”

While Narrative Health may share your Personal Information with your consent as outlined in our Privacy Notice, there may be limited instances where our sharing of information may be considered a “sale” under CCPA.

You have the right to opt-out of the sale of your Personal Information. You can also submit a request by email at to team@narrative-health.com, via phone at +1-917-702-0241 or via postal mail at Narrative Health LLC, 188 Grand Street, 2nd & 3rd Floor #39, New York, NY 10013, Attn: Avanti Ananthram, Managing Director.

Please be advised that if you exercise this right, it may affect our ability to offer you opportunities to participate in our research studies.

You have the opportunity to choose (opt out) whether your personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you.

Financial Incentives

Narrative Health provides Healthcare Professionals, Patients, Caregivers and others with the opportunity to participate in market research studies.

If you participate in a study that we sponsor, the recruitment agency who manages your participation will provide you with financial incentives which can be in the form of cash, vouchers, gift cards and/or reward points or other options.

By accepting these financial incentives, you agree that these considerations represent fair value for your participation in the research studies you complete for us.

Response Timing and Format

We endeavor to respond to a verifiable request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding receipt of a verifiable request.  The response we provide will also explain the reasons we cannot comply with a verifiable request, if applicable.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Changes to this Notice

This Notice may be amended from time to time, consistent with applicable data protection and privacy laws and principles. We will notify you if we make changes that materially affect the way we handle Personal Information previously collected, and we will allow you to choose whether their Personal Information may be used in any materially different manner.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at team@narrative-health.com, via phone at +1-917-702-0241 or via postal mail at Narrative Health LLC, 188 Grand Street, 2nd & 3rd Floor #39, New York, NY 10013, Attn: Avanti Ananthram, Managing Director.