This Data Privacy Framework Policy (“Policy”) applies to IQVIA Inc. and its U.S. operating subsidiaries (including those entities listed in Exhibit A) (collectively referred to as “IQVIA,” “Company,” “we” or “our”) when Personal Information is received from or about Individuals in the European Economic Area (EEA), United Kingdom (UK), or Switzerland in any format including electronic, paper or verbal. IQVIA respects the relationships we have with our customers and respects the privacy of all Individuals whose Personal Information (see Definitions) may be processed by IQVIA in the performance of our services and our business operations.

To demonstrate our commitment to the protection of Personal Information, including Personal Information transferred out of the EEA, UK, and Switzerland for the performance of our services and business operations in the United States, IQVIA complies with the EU-U.S. Data Privacy Framework (“DPF”), the UK extension to the DPF (“UK Extension”), and the Swiss-U.S. Data Privacy Framework (“Swiss DPF”), respectively, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EEA, UK, and Switzerland to the United States.

IQVIA has certified with the Department of Commerce that it adheres to the DPF Principles. If there is any conflict between the terms in this Policy and the DPF Principles, the DPF Principles shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/s/. We also use standard contractual clauses and other mechanisms approved by the European Union for certain transfers of Personal Information to the United States from the EEA, UK, and Switzerland.

This Policy supplements IQVIA’s General Privacy Policy and Online Privacy Policy (collectively, they comprise IQVIA’s “Privacy Policies”).

Advisory: Please note that we are awaiting on an adequacy decision for data transfers from Switzerland made pursuant to the DPF. Once that adequacy decision becomes approved, we will also rely on the Swiss DPF for data transfers from Switzerland. We currently rely on alternative data transfer mechanisms, such as standard contractual clauses, for such data transfers.

SCOPE: This Policy applies to all Personal Information of Individuals received by IQVIA in the U.S. from the EEA, UK, or Switzerland, including Personal Information of consumers, healthcare professionals, patients, medical research subjects, clinical investigators, customers, suppliers, vendors, job applicants, business contacts and partners, investors, and government officials. Further information concerning how IQVIA collects, uses, shares and safeguards the Personal Information of Company Personnel is available in IQVIA’s internal privacy policies (and they are made available to Individuals to whom they pertain). This Policy will help you understand how IQVIA collects, uses, shares and safeguards Individuals’ Personal Information, and how, in certain circumstances, you can elect whether or not to allow your Personal Information to be used or shared. IQVIA endeavors to collect, use and disclose Personal Information in a manner consistent with the laws of countries in which it does business, and also has a tradition of upholding the highest ethical standards in its business practices.

LIMITATIONS ON SCOPE:

Adherence to the DPF Principles may be limited (i) to the extent required or allowed by applicable law, rule or regulation; (ii) to the extent necessary to respond to lawful requests by public authorities, including to meet national security, law enforcement, legal or governmental requirements; and/or (iii) to protect the health or safety of an Individual. Also, this Policy may not apply or may be limited when Personal Information is collected or processed by the following:

• IQVIA, under an agreement that contains the requisite standard contractual clauses approved by the European Commission with respect to the Personal Information;
• IQVIA, when necessary for the performance of a contract (e.g., an employment contract) between an Individual and IQVIA; or
• Any IQVIA affiliate, successor, subsidiary, business division or group that makes a separate certification to DPF, whether or not such certification covers only part of or all types of Personal Information in scope of this Policy.

DEFINITIONS: For purposes of this Policy, the following definitions shall apply:

• “Agent” means any third party that uses Personal Information provided to it by IQVIA to perform tasks on behalf of and/or under the instructions of IQVIA or to which IQVIA discloses Personal Information for use on its behalf.
• “European Economic Area” means for the purposes of this Policy the following thirty (30) countries: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Italy, Ireland, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden (i.e. countries within the European Union), and Iceland, Liechtenstein, and Norway.
• “Individual” means any natural person located in the EEA, UK, or Switzerland whose Personal Information is shared with IQVIA in the United States.
• “Personal Information” means any information or set of information about an identified or identifiable individual, including, but not limited to: (a) first name or initial and last name; (b) home or other physical address; (c) telephone number; (d) email address or online identifier associated with the individual; (e) Social Security number or other similar identifier; (f) employment, financial or health information; or (g) any other information relating to an individual that is combined with any of the above. The term “Personal Information” does not include non‐identifiable information or information that is reported in the aggregate (provided that such aggregated information is not identifiable to a natural person).
• “Personnel” includes, but is not limited to, any employee (permanent or temporary), director, officer, contractor, worker, temporary worker, job applicant, retiree of IQVIA and any and all of their respective dependents.
• “DPF Principles” collectively mean the seven (7) privacy principles, as well as the supplemental privacy principles and the associated guidance, details of which can be found at https://www.dataprivacyframework.gov/s/article/Participation-Requirements-Data-Privacy-Framework-DPF-Principles-dpf.
• “Sensitive Personal Information” means Personal Information subject to specified extra protection under the EU Data Protection Directive of 95/46/EC, the European Union General Data Protection Regulation, the UK General Data Protection Regulation, or any superseding legislation, such as race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data where processed to uniquely identify a person, or that concerns medical or health conditions or sex life. In addition, IQVIA will treat as Sensitive Personal Information any information received from an employee or third party where that employee or third party treats and identifies the information as sensitive.

Capitalized terms not defined above have the definitions set forth in the respective paragraphs of this Policy.

NOTICE

Where IQVIA collects Personal Information directly from Individuals, it will explain the purposes for which it collects and uses Personal Information about the Individuals, the types of third parties to which IQVIA discloses that information, and the choices and means, if any, IQVIA offers Individuals for limiting the use and disclosure of Personal Information about them. Notice will be provided in clear and conspicuous language. This explanation will be provided as soon as practicable and, in any event, before IQVIA discloses the Personal Information or uses such information for a purpose materially different than that for which it was originally collected or processed. Where IQVIA receives Personal Information from its subsidiaries, affiliates or other entities, including when acting as a Contract Research Organization (CRO) processing Personal Information under the direction of a customer, it will use such information in accordance with the notices provided by such entities and the choices made by the Individuals to whom such Personal Information relates.

In circumstances in which IQVIA obtains personal data as a service provider for its clients or affiliates, IQVIA’s clients or affiliates are responsible for providing appropriate notice to the Individuals whose personal data are transferred to the U.S. and obtaining any requisite consent (unless this function has been delegated to IQVIA).

• Research Studies-Related Information. For Individuals participating in research studies being managed by IQVIA as a CRO or in other situations where IQVIA is participating in research studies, including patients, their spouses/partners, caregivers, and relatives, clinical investigators or other study personnel, and other consultants, contractors, managers, and agents (who are natural persons) of the study sponsor and its corporate affiliates, business partners and third‐party service providers, Personal Information may be used in order to carry out the applicable studies and other study‐related services and/or pharmacovigilance. This may include the transfer of such Personal Information to the applicable study sponsor, its corporate affiliates, business partners and third‐party service providers performing services related to the study (e.g., study data management, clinical research monitoring services, safety monitoring, etc.).
• Human Resources-Related Information. For Individuals who are Personnel, we will process Personal Information to carry out and support our human resources functions and activities, including but not limited to, (i) evaluation of qualifications for an employment position; (ii) provision of employment benefits; (iii) administration and management of employees, compensation, stock options, grants and purchase plans, bonuses, retirement, training, and career planning; (iv) utilizing employee skills and ongoing employee resource allocation; (v) communicating with employees or their emergency contacts; (vi) administration of the company's business including budgeting, manpower planning, and organizational design; (vii) authentication of the individual's identity when gaining access to computer system applications; (viii) Personal Information data changes; (ix) employment status changes; (x) travel and expense planning and reimbursement; and (xi) evaluation of employee performance and time management; and (xi) management of Personnel performance, and implementation, investigation and reporting on compliance and discipline procedures and matters. IQVIA may provide Personal Information to Agents to support IQVIA in performance of these human resources‐related activities. Further information concerning how IQVIA collects, uses, shares and safeguards the Personal Information of Company Personnel is available to IQVIA Company Personnel in IQVIA’s internal privacy policy. In addition, for job applicants, Personal Information will be used for the evaluation of suitability of the applicant for a position. IQVIA may, under its discretion and with the consent of the candidate where required by law or otherwise obtained, perform such background checks as deemed appropriate to evaluate this suitability.
• Business Contacts. For Individuals who are business contacts of IQVIA, IQVIA may collect personal information concerning contact information for such business contacts. This information may be used for purposes consistent with the provision of information by these contacts, which may include marketing activities focused on sales of new products and services, requests to participate in market research that enhance IQVIA’s product offerings and other business activities.
• Health Care Professionals. IQVIA collects information about health care professionals directly from the health care professionals, from public sources and from business partners. We use this information in connection with various health care activities, including clinical trials, real world studies of patient treatment, health care outcomes analysis, market research activities, and other situations where primary intelligence from health care professionals is applicable.
• Customers and Program Participant Information. For Individuals sharing Personal Information with IQVIA in order to inquire about or otherwise make use of our services or purchase, receive or seek information, including about any health care products and services, opportunities to participate in clinical research, health care education and patient support programs which may be available through IQVIA, we will use such Personal Information in order to provide the requested information, products, and/or services. Such uses may include, but is not limited to, processing requested transactions, improving the quality of our services, sending communications about the products and services available through IQVIA, and enabling our business partners and Agents to perform certain activities on our behalf.
• Data Analytics Functions. In certain situations, IQVIA obtains and processes information about Individuals for various data analytics purposes. In most situations, this data has been anonymized or de‐identified and is no longer Personal Information when it is obtained by IQVIA (or when it is transferred to the United States). In some situations, IQVIA receives Personal Information from a customer or other data supplier for the purpose of such anonymization or de‐identification. In other situations, the data that is obtained and processed by IQVIA is pseudonymous. This pseudonymous information may be used for research purposes, primarily in connection with academic partners, with academia, and may be transferred by IQVIA to the United States as part of these research-related activities. For all of these situations, IQVIA’s activities are consistent with the notice and choice provided by these customers or data suppliers to Individuals, and IQVIA’s use of this information is consistent with IQVIA’s obligation to provide services to these entities. In those situations, and where such information is transferred to the United States, IQVIA uses such information only in manners consistent with the DPF Principles and the manner in which this data was obtained.

IQVIA may also use the Personal Information collected above to comply with our legal and regulatory obligations, policies and procedures, and for internal administrative purposes.

CHOICE

IQVIA will offer Individuals the opportunity, where practical and appropriate, to choose (optout) whether their Personal Information is (a) to be disclosed to a non‐agent third party, or (b) to be used for a purpose materially different from the purpose for which it was originally collected or subsequently authorized by the Individual.

IQVIA will not process Sensitive Personal Information about Individuals for purposes other than those for which the information was originally obtained or subsequently authorized by the Individual unless the Individual explicitly consents to the processing (“opt‐in”), or as required or permitted, or where not prohibited by law or regulation.

In some cases, even if an Individual opts‐out of disclosures of their Personal Information, IQVIA may still disclose such Personal Information (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce IQVIA policies or contracts; (v) to collect amounts owed to IQVIA; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) in the good faith belief that disclosure is otherwise necessary or advisable. IQVIA also may transfer Personal Information when a material event concerning its business operation(s), assets or shares, such as purchase, disposal, merger, joint venture or acquisition, is proposed or occurs. In such an event, IQVIA will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Policy. IQVIA will provide Individuals with reasonable mechanisms to exercise their choices to the extent required by applicable law.

ONWARD TRANSFER

In most situations, transfers to third parties are covered by the provisions in this Policy regarding notice and choice.

IQVIA does not sell or otherwise disclose Individuals’ Personal Information, except as described in our Privacy Policies or in a notice provided to Individuals at the time of collection, or as Individuals explicitly consent. IQVIA may share Individuals’ Personal Information with our service providers, consultants and affiliates for our and our affiliates’ internal business purposes or to provide Individuals with a requested service.

IQVIA will endeavor to only transfer Personal Information to a third party/Agent where such third party/Agent has given assurances that it provides at least the same level of privacy protection as required by the DPF Principles and this Policy and will notify IQVIA if it makes a determination it can no longer meet this obligation. IQVIA may, for example, provide an Individual's Personal Information to Agents to host our databases, for data processing services, or to send to that Individual the information that he or she requested. Where IQVIA has knowledge that an Agent is using or disclosing Personal Information in a manner contrary to the DPF Principles and/or this Policy, IQVIA will take reasonable steps to prevent or stop the use or disclosure. With respect to onward transfers to Agents, DPF requires that, to the extent it is responsible for the event, IQVIA shall remain liable should its Agents Process Personal Information in a manner inconsistent with the DPF Principles, and IQVIA accepts and shall follow this principle.

Where IQVIA knows that any third party to whom it has provided Personal Information is using or disclosing Personal Information in a manner contrary to this Policy and/or the DPF Principles, IQVIA will take reasonable steps to prevent or stop the use or disclosure. With respect to such onward transfers to Agents, and to the extent IQVIA is responsible for the event, IQVIA shall remain liable should its Agents process Personal Information in a manner inconsistent with the DPF Principles and this Policy.

In circumstances in which IQVIA obtains personal data as a service provider for its clients or affiliates, IQVIA’s clients or affiliates are responsible for protecting individual rights with respect to onward transfers. IQVIA has potential liability in cases of onward transfer to third parties of data of EU individuals received pursuant to the DPF Principles.

SECURITY

IQVIA will endeavor to take reasonable and appropriate technical, administrative and physical precautions designed to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Information IQVIA is processing, and regardless of whether such Personal Information is in electronic or tangible, hard copy form.

DATA INTEGRITY AND PURPOSE LIMITATION

IQVIA endeavors to use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the Individual. IQVIA will take reasonable steps designed to ensure that only Personal Information that is relevant to its intended use, accurate, complete, current, and otherwise reliable in relation to the purposes for which the information was obtained is used by IQVIA for as long as IQVIA retains possession of such information. IQVIA’s Personnel have a responsibility to assist IQVIA in maintaining accurate, complete and current Personal Information. When acting as a CRO or in other situations where IQVIA acts on behalf of another entity, IQVIA endeavors only to process Personal Information that is relevant to the services it provides, and only for purposes compatible with those for which the Personal Information was collected. Where IQVIA processes Personal Information as a CRO or otherwise acts under the direction of its customers, IQVIA works with such customers so that the customers can provide a way for Individuals to correct or update their Personal Information.

ACCESS

IQVIA will, on request, provide an Individual with confirmation regarding whether IQVIA is processing Personal Information about them. In addition, upon request of an Individual, IQVIA will take reasonable steps to correct, amend, or delete their Personal Information that is found to be inaccurate, incomplete or processed in a manner non‐compliant with this Policy or the DPF Principles, except where the burden or expense of providing access would be disproportionate to the risks to that Individual’s privacy, where the rights of persons other than the Individual would be violated or where doing so is otherwise consistent with DPF Principles. Unless prohibited by applicable law, IQVIA reserves the right to charge a reasonable fee to cover costs for providing copies of Personal Information requested by Individuals.

In circumstances in which IQVIA maintains personal data as a service provider for its clients or affiliates, IQVIA ’s clients or affiliates are responsible for providing Individuals with access to their personal data and the right to correct, amend or delete the data where it is inaccurate. In these circumstances, Individuals should direct their questions to the appropriate IQVIA client or affiliate. If they do not receive a response, IQVIA will provide reasonable assistance in forwarding the Individual’s request.

RECOURSE, ENFORCEMENT AND LIABILITY

IQVIA encourages Individuals covered by this Policy to raise questions about the processing of Personal Information about them by contacting IQVIA through the contact information provided below. Any Personnel that IQVIA determines is in violation of the DPF Principles and/or this Policy will be subject to disciplinary action up to and including termination of employment, where applicable, in accordance with IQVIA’s disciplinary procedures.

In accordance with the DPF Principles, IQVIA commits to resolve complaints about Individuals’ collection or use of your Personal Information. Any Individuals with inquiries or complaints regarding this Policy or the use or disclosure of Personal Information in accordance with the DPF Principles should first contact IQVIA using the contact information given below. IQVIA will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the DPF Principles outlined in this Policy. In addition, IQVIA has further committed to cooperate with the panel established by the EU data protection authorities (“DPAs”) and comply with the advice given by the panel with respect to unresolved DPF complaints related to Individuals’ human resources data transferred from the EEA in the context of the employment relationship. IQVIA also commits to cooperate with the Swiss Federal Data Protection and Information Commissioner (FDPIC) and the UK’s Information Commissioner’s Office (ICO) and to comply with the advice given by such authorities with regard to human resources data transferred from Switzerland and the UK in the context of the employment relationship. If you do not receive timely acknowledgement of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact your DPA for more information or to file a complaint. The services of DPAs (including the FDPIC and the ICO) are provided at no cost to Individuals. If any request remains unresolved, Individuals may, under certain circumstances, have a right to invoke binding arbitration under DPF; for additional information, see https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf. The Federal Trade Commission has jurisdiction over IQVIA’ compliance with the DPF Principles.

In addition, IQVIA has agreed to cooperate with JAMS with respect to complaints of Individuals that are not Personnel of the Company and with the local data protection authorities with respect to Personnel and human resources-related information. For more information and to submit a complaint to JAMS, visit https://www.jamsadr.com/eu-us-data-privacy-framework. Such independent dispute resolution mechanisms are available to Individuals free of charge. Under certain limited conditions, if your complaint is not resolved through these channels, it may be possible for Individuals to invoke binding arbitration before the EU-U.S. DPF Panel to be created by the U.S. Department of Commerce and the European Commission. For additional information, please visit https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

In circumstances in which IQVIA obtained or maintains Personal Information as a CRO or other Service Provider, Individuals may submit complaints concerning the processing of their Personal Information to the relevant client, in accordance with the client’s dispute resolution process. IQVIA will participate in this process at the request of the client or the Individual. IQVIA will take steps to remedy any issues arising out of potential failure to comply with the DPF Principles.

CONTACT INFORMATION: Questions, comments, concerns or complaints regarding this Policy or IQVIA's processing of Personal Information should be submitted to IQVIA by clicking here.

RESERVATION OF RIGHTS: IQVIA reserves the right to share an Individual’s Personal Information and contracts with Agents as required or authorized by law or regulation or in response to duly authorized information requests of government authorities.

CHANGES TO THE POLICY: This Policy may be reviewed and amended from time to time, without advance notice, to ensure that an appropriate level of protection for Personal Information is maintained. All amendments will be posted on this website. Please check back periodically for updates to this Policy.

POLICY - EFFECTIVE DATE: October 10, 2023

Exhibit A

• 159 Solutions, Inc.
• Advanced Health Media, LLC
• AllCare Plus Pharmacy Appature, Inc.
• BUZZEOPDMA LLC
• Cambridge Pharma Consultancy, Inc.
• Clinical Financial Services, LLC
• Clinical Solutions Group DATA
• NICHE ASSOCIATES, INC.
• DMD Marketing Corporation DrugDev Inc.
• EA Institute LLC Epernicus, LLC
• Foundry Health Health Practices Research Institute (HPRI)
• Highpoint Solutions LLC Inteliquet, Inc.
• INTERCONTINENTAL MEDICAL STATISTICS INTERNATIONAL, LTD. (DE)
• IQVIA Biotech (f/k/a Novella Clinical)
• IQVIA Government Solutions Inc.
• IQVIA Market Intelligence LLC
• IQVIA Phase One Services LLC
• IQVIA RDS Consulting Inc.
• IQVIA RDS Inc.
• IQVIA RDS Latin America LLC
• IQVIA Transportation Services Corp. Linguamatics Solutions Inc.
• MED-VANTAGE, INC.
• Myriad RBM, Inc.
• Outcome Sciences LLC
• Pharma Source Inc.
• Pharmaspectra US, LLC
• Polaris Management Partners, LLC
• Polaris Solutions LLC
• Prometheus Research Q Squared Solutions Holdings LLC
• Qcare Site Services, Inc.
• QualityMetric LLC
• Quintiles BioSciences Holdings, LLC
• Quintiles Commercial US, Inc.
• Quintiles Phase One Services, LLC
• Quintiles, Inc. Rivermark, LLC
• Secureconsent, LLC
• Targeted Molecular Diagnostics, LLC
• THE AMUNDSEN GROUP, INC.
• Themis North America Inc.
• VCG&A Inc.