Precision Discovery respects individual privacy and value the confidence of its customers, employees, clinical trial participants, consumers, business partners and others.
 

Privacy and Policy

Precision Discovery respects individual privacy and values the confidence of its customers, employees, clinical trial participants, consumers, business partners and others. Not only does Precision Discovery strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles Precision Discovery follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.

SAFE HARBOR

Precision Discovery complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Precision Discovery. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Precision Discovery’s certification, please visit http://www.export.gov/safeharbor/

SCOPE

This Safe Harbor Privacy Policy (the “Policy”) applies to all personal information received by Precision Discovery in the United States from the EEA and from Switzerland, in any format, including electronic, paper or verbal.

DEFINITIONS

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

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Precision Discovery or to which Precision Discovery discloses personal information for use on Precision Discovery’s behalf.

“Precision Discovery” means Precision Discovery Inc., its predecessors, successors, subsidiaries, divisions and groups in the United States.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of Precision Discovery to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, Precision Discovery will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

The privacy principles in this Policy have been developed based on the Safe Harbor Principles.

NOTICE: Where Precision Discovery collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which Precision Discovery discloses that information, the choices and means, if any, Precision Discovery offers individuals for limiting the use and disclosure of personal information about them, and how to contact Precision Discovery. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Precision Discovery, or as soon as practicable thereafter, and in any event before Precision Discovery uses or discloses the information for a purpose other than that for which it was originally collected.

Where Precision Discovery receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: Precision Discovery will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, Precision Discovery will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Precision Discovery will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY: Precision Discovery will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Precision Discovery will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS: Precision Discovery will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where Precision Discovery has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Precision Discovery will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, Precision Discovery will grant individuals reasonable access to personal information that it holds about them. In addition, Precision Discovery will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY: Precision Discovery will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: Precision Discovery will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Precision Discovery determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Precision Discovery Privacy Office at the address given below. Precision Discovery will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy.

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by Precision Discovery to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the Precision Discovery Privacy Office by mail to:

Precision Discovery
Privacy Office
Precision Discovery Inc.
25 W 45th Street Suite 701
New York, NY 10036

CHANGES TO THIS SAFE HARBOR

PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the Precision Discovery web page (www.PrecisionDiscovery.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.

To learn more about the Safe Harbor program, and to view Precision Discovery’s certification, please visit http://www.export.gov/safeharbor/