PRIVACY POLICY

Effective: February 24, 2020

PRIVACY STATEMENT

Introduction

Pharmaspectra US, LLC (“Pharmaspectra US”) is a Delaware Limited Liability Company with its principal place of business located at 210 Main Street, Madison, New Jersey (United States). Pharmaspectra US, together with its affiliates Pharmaspectra Group Ltd and Pharmaspectra Informatics PVT LTD shall be referred to herein together as the “Company.” This statement (“Privacy Statement”) sets forth the privacy standards that the Company utilizes to collect, retain, and use personal data obtained from or about individuals located within the European Union (“EU”) and the European Economic Area (“EEA”), as well as from individuals located in Switzerland, the United States and elsewhere in the world. This Privacy Statement also sets forth the Company’s policy with respect to its participation in the U.S. Department of Commerce’s EU-U.S. and Swiss-US Privacy Shield Frameworks (see Section 17 below). It is the Company’s policy to respect, and protect, personally identifiable information obtained from individuals as set forth in this Privacy Statement.

There are certain provisions of this Privacy Statement that only apply to individuals from the EU or EEA. Those sections are denoted as “EU/EEA Data Subjects Only.”

There are certain provisions of this Privacy Statement that do NOT apply to individuals from the EU or EEA. Those sections are denoted as “Not Applicable to EU/EEA Data Subjects.”

You should also review our Terms and Conditions of use of the website, which can be found at https://www.pharmaspectra.com/terms-and-conditions/ and is applicable and binding upon you with respect to your use of the website and is incorporated herein.

  1. What Is the Scope of this Statement?

This Privacy Statement sets forth the principles under which the Company collects, uses, processes, retains, and discloses personal data and/or sensitive data in the United States or the European Economic Area (“EEA”) or elsewhere from individuals, including by and through our website located at https://www.pharmaspectra.com/ and services provided by the Company as referenced therein (together, the “website”) and information you provide to us based upon information from our website (i.e., if you send us an e-mail at an e-mail address identified on the website) or through our website (i.e., using contact us). This statement covers information received in electronic and all other formats.

  1. Terms

The terms “we“, “us” and “our” refer to the Company, and its officers, directors, owners, employees and agents.

The term “personal data” means any data which relates to a natural person (as opposed to a business or corporate entity) that makes you identifiable. As used herein and in connection with our business, the term personal data may include:

  • Names and contact information, including phone number, physical address, fax and e-mail, all only to the extent provided by you to us, or which you manifestly make public;
  • Potentially gender and nationality;
  • Title, position, business/company/institution name for whom you work or provide services as indicated in public information or as provided by you to us;
  • Referral source data (i.e., how you ended up at the website);
  • Any other similar information provided to us by you in connection with our services or through the website.

The term “data controller” means the person or entity which decides the purposes for which, and the way in which, any personal data is processed.

The term “data processor” means the person or entity which processes personal data on behalf of the data controller.

The term “processing” means any operation or set of operations performed on personal data. Processing includes, but is not limited to, the collection of data, the organizing of data, the recording or saving/storage of data, the altering of data, the using of data, the disclosing or transfer of data, the deleting or destruction of data, or the making available of data.

  1. What Information We Collect About You

We may collect all types of personal data about you as described in Section 2 above under the definition of “personal data.”

You agree that we may collect and process all such personal data that you provide to us, or that you or your employer (or other entity for whom you provide(d) services) manifestly make public through publication or otherwise, and/or any entity which retains us and provides to us to enable us to provide the services (the “Services”) for which we were retained by said customer and as otherwise set forth in the agreement related to such Services. In addition to the Services identified on the website, these Services may also include Services in connection with the use and management of the website and all content and services therein.

You also hereby consent that we may use your personal data for the following additional purposes which may be included in, or part of, the Services:

  • Updating our records;
  • In connection with any application for employment with the Company;
  • Internal analysis for our business management purposes;
  • Any statutory or regulatory purpose which requires the processing of your personal data;
  • Legal and regulatory compliance;
  • Fraud and crime prevention;
  • Internal or external audits; and
  • Any other purpose for which valid consent is obtained.

In addition to the above, we may also collect other data from you which is not personal data, such as information about your employer, the content of articles or other information you publish or otherwise make public, etc.

Please do not supply the following to us:

  • Any other person’s personal data, unless the Company explicitly asks you to do so;
  • Any categories of your personal data that have not been explicitly requested by the Company;
  • Any confidential, proprietary, secret or legally protected information which you are not explicitly requested by the Company to provide; and
  • Any confidential, proprietary, secret or legally protected information which are under any legal obligation to not provide to or share with the Company.

  1. How We Collect Information About You

We collect information about you (including personal data) when:

  • You Give Us Information – You may provide us information when:
  • you set up an account with us; you provide it to us by filling out forms;
  • you send us e-mail; you provide information via phone or in person;
  • you provide us with information in writing and send it to us other than via e-mail, phone or in person (i.e., mail, FedEx, etc.);
  • you provide us with documentation;
  • you provide us with information which may contain personal data;
  • you provide it to use through our “Contact Us” page on the website;
  • you provide us with information in connection with seeking employment with the Company.
  • We Collect Information Automatically – We automatically collect certain types of information when you visit our website (as explained below).
  • We Collect Information From Other Sources – We may also obtain information about you from outside sources. For example, we may obtain commercially available information about you from third-parties or purchase e-mail lists from third parties for advertising and marketing purposes. We may also receive information from third-parties who provide services for us through web-beacons and other technologies described in this Privacy Statement.

  1. Use of Cookies

About Cookies

  • A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
  • Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
  • Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
  • Shared local objects (commonly referred to as “FLASH cookies”) are cookies that are placed on your computer that are not removed through normal browser management tools. If we use FLASH cookies, we will only do so in a manner consistent with the purposes for which they were designed unless you are specifically notified that we intend to use them for a specific service.

Cookies That We Use

We use cookies for the following purposes related to the services we provide for and to you and our users:

  • authentication – we use cookies to identify users of the website and/or the location of individuals accessing the website;
  • status – we use cookies to help us to determine if you are logged into our website;
  • personalization – we use cookies to store information about your preferences and to personalize the website for you;
  • security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

EU/EEA Data Subjects OnlyYou have the right to disable advertising cookies. However, the website does not use advertising cookies;

  • analysis – we use cookies to help us to analyze the use and performance of our website and services; and
  • cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Cookies Used By Our Service Providers And Vendors

Our service providers and vendors may use cookies and those cookies may be stored on your computer when you visit our website. These service providers and vendors may include, but may not necessarily be limited to:

Google Analytics (see https://support.google.com/analytics/answer/6004245?hl=en and information therein).

  • You should review the privacy and cookie policies of the above website to learn more about the cookies that are used in connection with the above.
  • The above website and cookies may change from time to time as we use different vendors or service providers to provide some or all of the services offered or provided by the above services and websites, or additional services we decide to include. While we will periodically update our list of such vendors and service providers, the above list may not be complete at any given time.

Managing Cookies

  1. Use of Web Beacons, Clear-GIFs, Pixel Tags and JavaScript
  • Except as set forth herein, our use of web beacons, clear-gifs, pixel tags and JavaScript is critical to proper functionality our website, and disabling them may impact the functionality of the website and the services we provide.
  • We also may use “pixel tags” (also called “action pixels,” “web beacons” or “clear gifs”) and/or JavaScript plug-ins, placed on the website and in our emails to you.
  • These web beacons and plug-ins are small graphic images (typically that you cannot see) or code on a website or in an email message which are used for such things as recording webpages or advertisements clicked-on by a user, or for tracking the performance of email marketing campaigns. These devices help us analyze our users’ online behavior and measure the effectiveness of our website and our marketing.
  • We may also work with third-party service providers that help us track, collect, and analyze this information. Third-party entities with whom we have agreements may place these devices on the website and/or in emails to use information obtained from them such as pages viewed, emails opened and items upon which you may click in emails. These third-party providers may also place cookies onto your computer. Those third-party cookies may enable us to obtain aggregate demographic information and user statistics about you and your preferences from these third-party sources as well as our information we have about you. See above for more information on our cookies.
  • EU/EEA Data Subjects OnlyYou may be able to disable use of web beacons, clear-gifs, pixel tags and JavaScript if you provide us with notice as set forth in Section 13 hereof. However, doing so may impact your ability to use our website and/or our services and/or impact the cost of our services to you.

  1. Server Logs
  • A web “server log” is a record of activity created by a computer that delivers certain webpages to your browser. Certain activities that you perform on our website may record information in server logs. For example, if you enter a search term on the website or enter your login information, the server log may record the search term, the link you clicked on to bring you to our website and/or information about your browser, such as your IP address and the cookies set on your browser.

  1. How We Use Your Personal Data
  • We process your personal data identified in this Privacy Statement to perform the Services as defined above. The legal basis for this processing is your consent set forth herein, your consent based upon certain information you manifestly make public, as well as our contractual obligations.
  • We may process your personal data identified in this Privacy Statement where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings, alternative dispute resolution or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
  • We may process your personal data identified in this Privacy Statement where necessary for the purposes of managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
  • We may process your personal data identified in this Privacy Statement where such processing is necessary or advisable for compliance with a legal obligation to which we are subject (in the United States, the United Kingdom, the EEA, the EU or elsewhere), or in order to protect your vital interests or the vital interests of another natural person.

  1. Providing Your Personal Data To Others
  • We may disclose your personal data to our affiliate company located in India, Pharmaspectra Informatics PVT LTD.
  • We may disclose your personal data to our officers, directors, employees, and agents insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Privacy Statement, including to provide or potentially provide Services to you or for your benefit.
  • We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings, ADR or in an administrative or out-of-court procedure.
  • We may disclose certain of your personal data to the suppliers and subcontractors pursuant to separate consent provided by you to us.
  • The foregoing disclosures are made insofar as reasonably necessary, and only to the extent required, for assisting us in providing our Services to you, storing data and in connection with the administration of our business.
  • In addition to the specific disclosures of personal data set out in this Section 9, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings, alternative dispute resolution, or in an administrative or out-of-court procedure.

  1. International Transfers of Your Personal DataFor EU/EEA and Swiss Data Subjects Only
  • In this Section 10, we provide information about the circumstances in which your personal data may be transferred to countries outside the EEA (Austria, Belgium, Bulgaria, Czech Republic, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom) or the United Kingdom should the United Kingdom cease to be part of the EEA.
  • Pharmaspectra US, LLC is a New Jersey Limited Liability Company with its principal place of business located at 210 Main Street, Madison, New Jersey (United States). The European Commission has made an “adequacy decision” with respect to the data protection laws of the United States. In the event the Company transfers any of your personal data to a third party in the United States or elsewhere outside of the EEA, or the United Kingdom should the United Kingdom cease to be part of the EEA, such transfers will be protected by appropriate safeguards through the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en, or other similarly applicable law concerning the United Kingdom; or through the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks as set forth below.
  • By providing your personal data to the Company, you are agreeing to the transfer and processing of your personal data to and in the United States, India and any other countries as identified herein in accordance with this Privacy Statement. Such transfers and processing may include, but not be limited to, one or more transfers of your personal data to our affiliate company located in India, Pharmaspectra Informatics PVT LTD.
  • By using our Services, you are agreeing to the transfer and processing of your personal data to and in the United States, India and any other countries as identified herein in accordance with this Privacy Statement.

  1. Retaining And Deleting Personal Data
  • This Section 11 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
  • Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
  • We will retain your personal data:
  • to the extent your personal data that we hold was obtained from data you knowingly, intentionally and manifestly made public or which is in the public domain independent of any act or action of us, it will be retained in that form for as long as it is needed or required for the purposes for which we obtained the information from the public record, or as otherwise required by applicable law;
  • to the extent your personal data that we hold was pulled by us and separated from data you knowingly, intentionally and manifestly made public or which is in the public domain independent of any act or action of us, it will be retained by us for as long as required by us for the purpose for which it was obtained and as required by our contractual requirements with third-party clients or as otherwise required by applicable law.
  • In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based upon the performance of our Services, and any applicable industry and governmental standards.
  • We may also retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Amendments
  • We may update this Privacy Statement from time to time by publishing a new version on our website.
  • You should check this page occasionally to ensure you are happy with any changes to this Privacy Statement.
  • We may notify you of significant changes to this Privacy Statement by email or through the private messaging system on our website.

  1. Your Rights – EU/EEA Data Subjects Only</li>
  • In this Section 13, we have summarized the rights that EU/EEA data subjects have under applicable data protection law, including the GDPR. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
  • Your principal rights under data protection law are:
  • the right to access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent under certain circumstances.
  • You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
  • You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
  • In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing where no other legitimate basis for retention exists; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation (including contractual obligations); or for the establishment, exercise or defense of legal claims.
  • In some circumstances you may have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
  • You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
  • You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
  • You have certain rights to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
  • If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
  • To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
  • If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Statement, please provide us with your exact name and address and advise us that you wish to opt-out for information sharing or receiving information from us or both as the case may be. Please note that de-identified and aggregate data including your personal information may still be shared, but it will not be identified or identifiable to you. Please direct your opt-out request, or your request to exercise any of your rights in relation to your personal data by written notice to us at:

Pharmaspectra US, LLC

210 Main Street, 2nd Floor

Madison, New Jersey 07940 (United States)

Attention: Privacy Officer (privacy@pharmaspectra.com)

 

With a copy (including the words “Pharmaspectra – GDPR” in the subject line) to:

OlenderFeldman LLP

422 Morris Avenue

Summit, NJ 07901 (United States)

Attention: Michael J. Feldman, Esq.

(mfeldman@olenderfeldman.com)

  1. Your Choices About Information We Collect – Not Applicable to EU/EEA Data Subjects
  • If you do not consent to the way in which we may use your personal information, please do not submit any personal information to us. Please note that if you do not provide us with certain personal information the Company may be unable to provide you with its Services, or those Services may not be as good as they otherwise could be.
  • If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Statement, please provide us with your exact name and address and advise us that you wish to opt-out for any information sharing or receiving information from us or both as the case may be. Please note that de-identified and aggregate data including your personal information may still be shared, but it will not be identified or identifiable to you. Please direct your opt-out request to the following contacts:

Pharmaspectra US, LLC

210 Main Street, 2nd Floor

Madison, New Jersey 07940 (United States)

Attention: Privacy Officer (privacy@pharmaspectra.com)

 

With a copy (including the words “Pharmaspectra – Privacy” in the subject line) to:

OlenderFeldman LLP

422 Morris Avenue

Summit, NJ 07901 (United States)

Attention: Michael J. Feldman, Esq.

(mfeldman@olenderfeldman.com)

  1. Privacy of Children Who Visit the Website

We recognize the importance of children’s safety and privacy. The website is not designed to attract children, and is not intended for use by any children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18. If you are under age 18, you do not have permission to use this website or our Services.

  1. Your California Privacy Rights
  • We collect various types of personal information about you during the course of your relationship with us. Under California law, if you are a resident of California, you may make a written request to us about how we have shared your information with third parties for their direct marketing purposes. In response to your written request, we are allowed to provide you with a notice describing the cost-free means to opt-out of our sharing your information with third parties with whom we do not share the same brand name, if the third party will use such information for its direct marketing purposes.
  • If you would like to exercise your rights under California law, please send your written request to the e-mail address or postal address below. Please include your postal address in your request and the words “CALIFORNIA OPT-OUT” in the subject line of your request. Within thirty (30) days of receiving your written request, we will provide you with a Third Party Direct Marketing Opt-Out Form so you may request that your personal information not be disclosed to third parties for their direct marketing purposes.

E-mail Address:

privacy@pharmaspectra.com

Postal Address:

Pharmaspectra US, LLC

210 Main Street, 2nd Floor

Madison, New Jersey 07940 (United States)

Attention: Privacy Officer

  1. Our Privacy Shield Statement For EU/EEA and Swiss Data Subjects Only

Pharmaspectra US is a participant in the U.S. Department of Commerce’s EU-U.S. and Swiss-US Privacy Shield Frameworks and has certified that we adhere to the EU-U.S. and Swiss-U.S. Privacy Shield Principles. Pharmaspectra US is subject to the investigatory and enforcement powers of the Federal Trade Commission. For more information about the EU-U.S. and Swiss-US Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield website at https://www.privacyshield.gov/welcome.

  • Privacy Principles: The privacy principles in this Privacy Statement have been developed based on the Privacy Shield Principles.
  • Pharmaspectra US does not collect private information except as set forth herein.
  • Pharmaspectra US does not intentionally collect information from individuals under the age of 18.
  • Pharmaspectra US does not conduct any financial transactions through the website.
  • Any private information that is unintentionally collected by Pharmaspectra US is deleted from its databases promptly upon discovery of same.
  • Notice and Choice:
  • Information will only be collected from individuals in the EEA or Switzerland as set forth herein, and pursuant to the purposes, and subject to the rights and obligations, set forth herein.
  • Pharmaspectra US will offer individuals the opportunity to choose (opt-out) to the collection and use of personal information as set forth herein.
  • Data Integrity:
  • Pharmaspectra US will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized. Pharmaspectra US will take reasonable steps to ensure that personal information is relevant to its intended use, and is accurate, complete, and current to the extent applicable.
  • Transfers to Agents:
  • In cases of onward transfer to third parties of data of EEA or Swiss individuals received pursuant to the EU-U.S. and Swiss-US Privacy Shield Frameworks respectively, Pharmaspectra US remains liable.
  • Pharmaspectra US will obtain assurances from its agents that they will safeguard personal information consistently with this Privacy Statement. 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 Privacy Shield Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Privacy Shield certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where Pharmaspectra US has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Pharmaspectra US will take reasonable steps to prevent or stop the use or disclosure.
  • Access and Correction:
  • Upon request, and as set forth herein, Pharmaspectra US will grant individuals reasonable access to personal information that it holds about them. In addition, Pharmaspectra US will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
  • Security:
  • Pharmaspectra will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and/or destruction.
  • Enforcement:
  • Pharmaspectra US will conduct compliance audits of its relevant privacy practices to verify adherence to this Privacy Statement. Any employee knowingly, intentionally or negligently violating this Privacy Statement, as determined by Pharmaspectra US, 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 Pharmaspectra US Privacy Officer at the address given below:

E-mail Address:

privacy@pharmaspectra.com (using the term PRIVACY SHIELD in the subject line)

Postal Address:

Pharmaspectra US, LLC

210 Main Street, 2nd Floor

Madison, New Jersey 07940 (United States)

Attention: Privacy Officer – PRIVACY SHIELD

  • Pharmaspectra US will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Privacy Shield Statement. For complaints that cannot be resolved between Pharmaspectra US and the complainant, Pharmaspectra US has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Privacy Shield Principles:
  1. For disputes involving all personal information received by Pharmaspectra US from Switzerland, Pharmaspectra US has agreed and to cooperate with the Swiss FDPIC;
  2. For disputes involving employment-related personal information received by Pharmaspectra US from the EEA, Pharmaspectra US has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;
  3. For disputes involving all other personal information received by Pharmaspectra US from the EEA, Pharmaspectra US has agreed to PrivacyTrust dispute resolution. Individuals who submit a question or concern to Pharmaspectra US and who do not receive acknowledgment from Pharmaspectra US of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the PrivacyTrust Privacy Shield Dispute Resolution Program on the Internet, by mail or by fax. Inquiries by mail or fax should identify Pharmaspectra US as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether PrivacyTrust may share the details of the inquiry with Pharmaspectra US. PrivacyTrust will act as a liaison to Pharmaspectra US to resolve these disputes.
  4. PrivacyTrust: https://www.privacytrust.com/cert/397514.html.
  5. Pharmaspectra US contact: see above.
  6. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, you can also submit your complaint to Privacy Trust, an independent third party. Visit https://www.privacytrust.com/drs/Pharmaspectra to file a complaint.
  7. Finally, as a last resort and in limited situations, EEA individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
  • Limitation on Application of Principles:
  • Adherence by Pharmaspectra US to these Privacy Shield 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:
  • Any questions or concerns regarding this Privacy Shield Statement should be submitted to Pharmaspectra US by mail as follows:

Postal Address:

Pharmaspectra US, LLC

210 Main Street, 2nd Floor

Madison, New Jersey 07940 (United States)

Attention: Privacy Officer – PRIVACY SHIELD

  • Changes to this Privacy Shield Statement:
  • This Privacy Shield Statement may be amended from time to time, consistent with the requirements of the Privacy Shield Principles. All such changes will be posted to the Pharmaspectra US website for 60 days whenever this Privacy Shield Statement is changed in a material way.
© Pharmaspectra Group Limited, 2020
All Rights Reserved
2 Eastbourne Terrace
London, W2 6LG