Privacy Policy

Privacy Policy

Gray Consulting, Inc.

Privacy Policy

Last updated: June 12, 2017

Welcome!

We are Gray Consulting, Inc.  Through our Gray Consulting International Meetings & Incentives business division (“GCIMI”), we provide corporate meeting and event planning services to organizations (our “Clients”) in connection with certain events that they host (the “Events”), and we provide transportation and expense management solutions to our Clients and to participants in the Events.   Through our Clincierge business division (“Clincierge”), we provide organizations with administrative support in connection with clinical trials (the “Trials”), and we provide transportation and expense management solutions to our Clients and to participants in the Trials.  The services that we provide through GCIMI and Clincierge are collectively referred to herein as our “Services.”  Gray Consulting, Inc., GCIMI and Clincierge are collectively referred to herein as “we,” “us,” or “Gray Consulting.”  This Privacy Policy applies to the information collected online at www.gcimi.com, www.clincierge.com and www.clinciergeconnect.com (our “Sites”), as well as to information collected by us offline in connection with our Services.

THE INFORMATION THAT WE COLLECT

In the course of operating our Sites and providing our Services, we collect the following types of information:

  1. Information Collected in Connection with our Services

We collect certain personal information from you when you register for Event(s) or participate in Trial(s), and when we provide our Services to you in connection with such Event(s) or Trial(s).  The personal information that we collect includes your first and last name, mailing address, email address, travel information relating to your travel plans to and from the Event(s) or Trial(s), and any other information that you choose to provide to us.

  1. Other Information

We may collect other information about you.  This other information may be collected from visitors to our Sites to whom we do not provide our Services, as well as from individuals to whom we provide our Services, and it may include:

a.  From You.  Additional information about yourself that you voluntarily provide to us, such as your age, occupation or any other information about yourself, whether or not personally identifiable information.

b.  From Cookies and Other Technology.  Like most websites, we use automatic data collection technology when you visit the Sites to collect information that identifies your computer or device. This comprises information about your operating system, your IP addresses, browser type and language, referring pages and URLs, keywords, date and time, and what sections of our Sites you visit, as well as the universally unique ID (“UUID”), advertising identifier (“IDFA”), MAC address; operating system and version (e.g., iOS, Android or Windows), carrier and country location, hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled), network type (WiFi, 3G, 4G, LTE), and similar data (collectively, the “usage information”).  We collect this usage information by using cookies. Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. You can reject cookies by following the directions provided by your browser vendor or by your Internet provider’s “help” file. If you reject cookies, you may still visit the Sites, but you may not be able to use some areas of our Sites.  We use cookies (and the usage information collected) to help us identify you and analyze how you use our Sites.

We also work with trusted third party partners which use cookies to collect usage information about how users use our Sites, for example, which pages users go to most often, and if they get error messages on those pages.  The usage information gathered is only used to improve how our Sites work. The trusted third parties we currently work with include the following (click on the links to view these organizations’ privacy policies and find out more about what data they hold about you, what they do with it, and how to opt-out from certain data collection):

Google Analytics – http://tools.google.com/dlpage/gaoptout

3.  Aggregate Data. In an ongoing effort to better understand our users of our Sites and the recipients of our Services, we may analyze Information in aggregate form to operate, maintain, manage and improve our Sites and Services.  This aggregate information does not identify you personally.  We may share this aggregate data with our affiliates, agents, and business partners, including, without limitation, our Clients. We may also disclose aggregated user statistics in order to describe the Sites or the Services to current and prospective business partners and to other third parties for other lawful purposes.

PURPOSE OF COLLECTION AND USE

We use the information that we collect from you under this Privacy Policy to provide our Sites and Services; to respond to general inquiries; to solicit feedback regarding our Sites and Services; to provide relevant content on our Sites, to send invoices and receive payments; to communicate with you regarding the Events or Trials that you have registered for, and to communicate with you regarding our current and future product and service offerings and those of our third-party marketing partners.

ONWARD TRANSFER TO THIRD PARTIES

We will share your personal information with our Clients in connection with their hosting and administration of the Event(s) or Trial(s) for which you register.  We may also share your personal information with our travel assistance partners, in connection with booking airfare, hotel and/or train reservations on behalf of you in connection with your attendance at such Event(s) or Trial(s).  With your prior approval, we may also share your personal information with your bank(s) for reimbursements of Event or Trial expenses that you are entitled to, as determined by the Client hosting the applicable Event or Trial.

Like many businesses, we hire other companies to perform certain other business-related services. We may disclose personal information to these companies but only to the extent needed to enable them to provide such services. The types of companies that may receive your personal information and their functions are: direct marketing assistance, billing, customer service, data storage, hosting services, sales support, logistics support, and technical assistance.  All such third parties function as our agents, performing services at our instruction and on our behalf pursuant to contracts which require they provide at least the same level of privacy protection as is required by this Privacy Policy and implemented by us. You may opt out of having your personal information transferred to any or all of our categories of agents by contacting us at privacy@gcimi.com. Please allow us a reasonable time to process your request.

OPT-IN TO CERTAIN ONWARD TRANSFERS

We will not transfer your personal information to a third party acting as a controller without first providing you with information regarding the identity of such controller or the nature of such controller’s business, and obtaining your opt-in consent.  You may grant such consent by contacting us at privacy@gcimi.com. Please allow us a reasonable time to process your response.

RELATED ENTITIES; BUSINESS TRANSFERS

We may share your personal information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us for aggregation, analysis and benchmarking purposes.

In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy.

DISCLOSURE TO PUBLIC AUTHORITIES

We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

OPT-OUT FOR DIRECT MARKETING

You may opt out at any time from the use of your personal information for direct marketing purposes by contacting us at privacy@gcimi.com.  Please allow us a reasonable time to process your request.

ACCESS TO YOUR PERSONAL INFORMATION

Upon request by sending an email to us at privacy@gcimi.com, we will provide you with confirmation as to whether we are processing your personal information, and have the data communicated to you within a reasonable time after your request. You have the right to correct, amend or delete your personal information where it is inaccurate or has been processed in violation of this Privacy Policy. We may require payment of a non-excessive fee to defray our expenses in this regard. Please allow us a reasonable time to respond to your inquiries and requests.

RETENTION OF PERSONAL INFORMATION

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. After such time periods have expired, we may either delete your personal information or retain it in a form such that it does not identify you personally.

HOW WE PROTECT YOUR PERSONAL INFORMATION

We take very seriously the security and privacy of the personal information that we collect pursuant to this Privacy Policy. Accordingly, we will implement reasonable and appropriate security measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations.

CHILDREN

We do not knowingly collect any personal information from children under the age of 13 through our Sites or Services.  If you are under the age of 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information to us without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at privacy@gcimi.com, and we will endeavor to delete that information from our databases.

LINKS TO EXTERNAL WEBSITES

Our Sites may contain links to third party websites, including, without limitation, those of Clients (“External Sites”). We have no control over the privacy practices of these External Sites. As such, we are not responsible for the privacy policies of those External Sites. You should check the applicable third party privacy policy and terms of use when visiting any External Sites, and before providing any personal information to such External Sites.

IMPORTANT NOTICE TO NON-US RESIDENTS

Our servers are located in the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US. Except in the case of data transfers under the EU-US Privacy Shield and the Swiss-U.S. Privacy Shield Framework, your decision to provide such data to us, or to allow us to collect such data through our Sites or through the provision of our Services, constitutes your consent to this data transfer.

IMPORTANT NOTICE FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA AND SWITZERLAND

We comply with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from the European Union member countries (including Iceland, Liechtenstein and Norway) and Switzerland to the United States, respectively. We have certified that we adhere to the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability (the “Privacy Shield Principles”). With regard to the Principle of Accountability for Onward Transfer, for example, we remain liable if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage. If there is a conflict between this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/ .

We are subject to the investigatory and enforcement powers of the Federal Trade Commission.

In compliance with the EU-US and the Swiss-U.S. Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact us at privacy@gcimi.com.  We have further committed to refer unresolved privacy complaints under the EU-US and the Swiss-U.S. Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. If these processes do not result in a resolution, you may also contact your local data protection authority, the US Department of Commerce, and/or the Federal Trade Commission for assistance. If your complaint still remains unresolved, then you have the right to invoke binding arbitration by the Privacy Shield Panel upon written notice to us at privacy@gcimi.com.

CALIFORNIA PRIVACY RIGHTS

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83 of the California Civil Code, please contact us via email at privacy@gcimi.com.

We do not monitor, recognize or honor any opt-out or do not track mechanisms including general web browner, “Do Not Track” settings and/or signals.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on our Sites as soon as they go into effect. By accessing or using our Sites or receiving our Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

HOW TO CONTACT US

If you have questions about this Privacy Policy, please contact in one of the following ways:

E-mail us at privacy@gcimi.com;

Call us at 215.413.2034;

Or write to us at:

Gray Consulting, Inc.
190 N. Independence Mall West, Suite 201
Philadelphia, PA 19106

Our Affiliations

PHL CVB NGLCC Clincierge MPI IBA