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Privacy Policy


GENERAL:

PharmaVigilant is committed to the privacy and security of its customers, employees, consumers, business partners and others. PharmaVigilant operates under a set of strict privacy principles, and strives to gather, use and disseminate personal information in accordance with the laws of the countries in which it does business.


SCOPE:

Please note that PharmaVigilant provides its clients with services that involve it processing personal data on its client's behalf, for instance where it supplies system trouble-shooting, data warehousing and application management services. In this capacity, PharmaVigilant's client owns and controls the personal data it processes. PharmaVigilant receives and processes personal data merely as a "data processor" on behalf of its client. As a data processor acting on behalf of a PharmaVigilant client, PharmaVigilant is not required to comply with the these principles but is required to perform its services in accordance with its contract with the client concerned and any data privacy protections incorporated therein. This Policy is to be read subject to this distinction.

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, PharmaVigilant or to which PharmaVigilant discloses personal information for use on PharmaVigilant's behalf.

"PharmaVigilant" means PharmaVigilant, 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 PharmaVigilant 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, PharmaVigilant will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

CHOICE:

PharmaVigilant will provide individuals an opportunity, at any time, to choose (through an 'opt out' choice) whether their personal data is to be disclosed to a non-agent third party, or used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For sensitive personal information, PharmaVigilant will give individuals the opportunity to affirmatively or explicitly consent (through an 'opt in' choice) 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 authorized by the individual.

DATA INTEGRITY:

PharmaVigilant will only process personal data in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, PharmaVigilant will take reasonable steps to ensure that personal data is accurate, complete, current and reliable for its intended use.

TRANSFER TO AGENTS:

PharmaVigilant will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Reasonable steps will be taken by PharmaVigilant if an agent is using or disclosing personal information in a manner contrary to this Policy.

ACCESS:

PharmaVigilant will grant an individual access to their personal data upon request and will provide reasonable measures to allow the correction, amendment or deletion of inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.

DATA SECURITY:

PharmaVigilant takes all reasonable security measures to protect against the loss, misuse, alteration and destruction of the information under our control.

ENFORCEMENT AND DISPUTE RESOLUTION:

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

PharmaVigilant encourages interested persons to raise any concerns using the contact information provided below and it will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information in accordance with the Safe Harbor principles.

CONTACT INFORMATION

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

PharmaVigilant Privacy Office
PharmaVigilant., Inc.
P.O. Box 587
Westborough, MA 01581

Or by e-mail to: jdesanti@pharmavigilant.com

CHANGES TO THIS PRIVACY POLICY:

This Policy may be amended from time to time. We will post any revised policy on this website (www.PharmaVigilant.com).