Privacy shield Policy

Privacy shield policy

Definitions

For the purposes of this Policy:

“EEA” means the European Economic Area;

“Envision Pharma Group”/“we”/“us”/“our” means Envision Pharma Group Limited and its subsidiaries including, without limitation:

Alligent Biopharm Consulting LLC

Engage Scientific Solutions Inc.

Excel Scientific Solutions Inc.

Curo Consulting Inc.

Envision Pharma Acquisition Inc.

ProScribe (US) LLC

Elevate Scientific Solutions LLC

Envision Pharma Inc.

Touch Creative Design LLC

Eloquent Scientific Solutions LLC

Envision Pharma US Holdco Inc.

 

EndPoint Technologies LLC

Evidence Scientific Solutions Inc.

 


“Personal Information”
 means any information or a set of information that identifies or is used by or on behalf of Envision Pharma Group to identify an individual;

“Sensitive Personal Information” means Personal Information consisting of information as to racial or ethnic origin; political opinions, religious or philosophical beliefs, or trade-union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Scope

Envision Pharma Group respects individual privacy and is committed to maintaining the privacy and security of the Personal Information of its clients, employees, business partners, and others with whom we interact. This policy sets forth the privacy principles that Envision Pharma Group currently follows with respect to transfers of Personal Information from the EEA and Switzerland to the United States.

Compliance

Envision Pharma Group complies with the principles of the US-EU and US-Swiss Privacy Shield Framework regarding the transfer of Personal Information from the EEA or Switzerland to the United States and has certified to the Department of Commerce that it adheres to the Privacy Shield principles. To view our certification, please visit https://www.privacyshield.gov.

Personal Information

This Privacy Shield Policy should be read in conjunction with our Privacy Policy and Cookies Policy. In particular, reference should be made to the following sections of our Privacy Policy as these describe generally how we deal with Personal Information:

  • What personal information we collect;
  • How we use personal information; and
  • Which countries we transfer personal information to.

Privacy Shield Principles

Envision Pharma Group commits to subject to the Privacy Shields’ Seven Principles all Personal Information received by it in the United States from the EEA and Switzerland in reliance on the respective Privacy Shield framework. Such principles are set out below.

1.             Notice

In addition to this policy and our Privacy Policy, we may need to explain specific privacy practices in more detail at other times. In such circumstances, we will develop and provide separate privacy notices to:

(1) disclose the purpose for collecting and using the Personal Information;

(2) describe the identity and contact details of the entity collecting the relevant Personal Information;

(3) the circumstances under which the collection of Personal Information is being made and the purposes for which it is being collected;

(4) describe the types of entities to whom disclosures may be made and the countries in which they are based;

(5) describe the choices and means, if any, offered by Envision Pharma Group to individuals to limit the use and disclosure of such Personal Information; and

(6) provide contact information to individuals where their inquiries or complaints can be addressed. Such notice will be provided at the time when individuals are first asked to provide Personal Information or as soon as practicable.

2.             Choice

Envision Pharma Group will offer individuals the opportunity to opt-out of further uses or disclosures when their Personal Information will be disclosed to a non-agent third-party or in connection with a purpose other than the purposes for which it was originally collected or authorized by the individual. If the use or disclosure involves Sensitive Personal Information, Envision Pharma Group will afford individuals the opportunity to explicitly opt-in to such use or disclosure when the Sensitive Personal Information would be disclosed to a non-agent third-party or in connection with a purpose other than the purposes for which it was originally collected or authorized by the individual.

3.             Data integrity

Envision Pharma Group will use Personal Information in its possession only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Envision Pharma Group will take reasonable steps to ensure that Personal Information is reliable for its intended use; and is accurate, complete and current.

4.             Onward transfers

Envision Pharma Group uses a limited number of contractors to assist us regarding our services, in relation to which Personal Information may be transferred to them. Envision Pharma Group will obtain adequate assurances from its agents and other business partners that they will safeguard Personal Information in a manner consistent with this policy. Envision Pharma Group may be liable if such contractors do not adhere to such obligations unless we prove that we are not responsible for the event giving rise to the relevant damage. 

5.             Access and correction

Envision Pharma Group will grant individuals reasonable access to Personal Information that it holds about them, unless such access would compromise the purpose for which it was collected. Envision Pharma Group will take reasonable steps to assist individuals with correcting, amending or deleting Personal Information that is determined to be inaccurate or incomplete. The foregoing shall not apply where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy in the case in question (but only to the extent legally permissible); where the rights of persons other than the individual would be violated; or where otherwise permitted under applicable law.

6.             Security

Envision Pharma Group will take reasonable and appropriate measures to protect Personal Information in its possession from loss, misuse, interference, unauthorized access, disclosure, alteration and destruction.

7.             Enforcement

Envision Pharma Group will verify its adherence to this policy by conducting routine compliance audits of its relevant privacy practices. Envision Pharma Group will take appropriate disciplinary action, consistent with applicable laws, against any Envision Pharma Group employee who willfully violates or seeks to circumvent this policy or its Privacy Policy or who takes an action to compromise the integrity or safety of Personal Information.

Dispute resolution

Any questions or concerns from EU and Swiss individuals regarding the use or disclosure of Personal Information should be directed to the address given below (under “Contact Information”). Envision Pharma Group will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this policy (including responding to the individual within 45 days).

For complaints regarding the US-EU or US-Swiss Privacy Shield principles that cannot be resolved between Envision Pharma Group and the complainant, Envision Pharma Group has agreed to participate in the dispute resolution procedures of JAMS (http://www.jamsadr.com/) for non-human resources data; EU Data Protection Authorities (DPAs) for HR data only. If none of these procedures resolve any complaint or dispute, a binding arbitration option will be available as explained in the Privacy Shield principles.

Regarding the US-EU and US-Swiss Privacy Shield arrangements, Envision Pharma Group is subject to the investigatory and enforcement powers of the US Federal Trade Commission.

Limitation on application of principles

Adherence by Envision Pharma Group to these principles may be limited to the extent:

(1) required to respond to a legal or ethical obligation;

(2) expressly permitted by an applicable law, rule or regulation, such as processing data specifically requested by government agencies for the purpose of medical safety;

(3) to the extent necessary to meet national security, public interest or law enforcement obligations; or

(4) to the extent that Envision Pharma Group has limited or no control over the actions of its clients regarding use of Personal Information that they have collected.

Contact information

Our Data Protection Officer can assist with any questions regarding this policy and can be contacted at either of the following:

Privacy@EnvisionPharmaGroup.com

Envision Pharma Group

FAO: The Data Protection Officer

26-28 Hammersmith Grove

London

W6 7HA

United Kingdom

Changes to this policy

Envision Pharma Group may revise or update this policy from time to time.

Last updated 18 May 2018