Data Privacy

EU-US PRIVACY SHIELD PRIVACY POLICY

Porzio Life Sciences, LLC (“PLS”) is dedicated to helping life sciences companies understand the regulatory environment that impacts their business, and it provides services and  compliance tools to life sciences companies to help them stay compliant with governing laws and codes.  In doing so, PLS receives personal information from or concerning individuals in the European Union (“EU”) from its customers.  Such personal information may include name, address, e-mail address, phone number, and/or other personal identifying information.  PLS also collects information from individuals in the EU when such individuals contact PLS and request information about its services.  PLS has established a comprehensive privacy program that has been designed to and is intended to protect your data privacy rights.

PLS complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from EU member countries. PLS has certified that it adheres to the EU-U.S. Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability.  If there is any conflict between the policies in 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/.

1.  Notice:  When PLS directly collects personal information from individuals in the EU, it, as explained below, advises you about the purposes for which the information is collected and used, and your ability to limit the use and disclosure of such information, and how to contact PLS.  Specifically, PLS directly collects personal information from EU individuals if you provide personal information to PLS when you contact us through our website or otherwise seeking information about our services.  If you provide information to us about our services, we will only use that information to contact you about our company and our services.  We will not sell or provide your information to any third party.  By submitting your personal information to us, via our website contact form or otherwise, you are consenting only to us sharing your personal information within PLS and its parent company, Porzio, Bromberg & Newman, which also complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce.  For more information about PLS, please see the “About Us” section of our website: http://porziolifesciences.com/about/.  PLS provides notice in clear and conspicuous language atthe time you provide such information to PLS or as soon as practicable thereafter.  When PLS receives personal information from entities/its customers to assist those customers comply with governing laws and codes, it uses such information consistent with the notices provided by such entities/customers that initially collected the information and the choices made by the individuals from whom the information was collected and in accordance with the principles of the Privacy Shield.  PLS only uses this personal information to assist its customers in complying with governing laws and codes.
2.  Choice:  PLS does not and does not intend to disclose personal information to a non-agent third party. Nor does PLS use or intend to use your personal information for any purpose other than that for which it was originally collected.  However, if PLS plans to disclose personal information to a non-agent third party or plans to use your personal information for any purpose other than that for which it was originally collected, it will contact you via the contact information you provided to PLS to provide you with the choice of whether to permit such use.  PLS will not disclose personal information to a non-agent third party or use personal information for a purpose other than that for which it was originally collected unless you affirmatively consent and opt-in to doing so.  Please use the contact information listed below if you have any questions about this.
3.  Onward Transfers:  When PLS transfers personal data to a third party that is acting as an agent, it enters into a written agreement with such third party requiring that the third party provide at least the same level of privacy protection as is required by the relevant principles of the Privacy Shield.  Third parties acting as agents that PLS engages include, but are not limited to, business partners or consultants that are utilized to assist PLS perform the services for which it was retained by the customer with respect to complying with governing laws and codes and that PLS carries out in accordance with the foregoing and pursuant to the purposes for which the information was initially collected.  PLS does not share data with non-agent third parties.  In cases of onward transfers to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, PLS is potentially liable, unless PLS proves that it is not responsible for the event giving rise to the damage. PLS may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet a national security or law enforcement request.
4.  Access:  PLS acknowledges that EU individuals have the right to access the personal information that it maintains about them.  PLS will provide individuals with reasonable access to information it has about them upon their request, and PLS will take reasonable measures to allow for the correction, amendment, or deletion of information that is shown to be incorrect or inaccurate.  You may contact PLS using the contact information below to learn whether or not PLS has your personal data subject to this policy, and to request corrections, amendments or deletion of such data. This right applies only to personal information about you and is subject to other limitations as defined by law, or where the burden or expense of providing access would be disproportionate to the risks related to the privacy of the individual or where the rights of other individuals would be violated. You will need to provide sufficient identifying information.
5.  Security:  PLS maintains various safeguards, including physical and electronic and managerial procedures, to protect the security and confidentiality of personal information that it has received.  PLS takes reasonable precautions to protect against unauthorized access, misuse, disclosure, destruction, or alteration of data in its control.
6.  Data Integrity:  The personal information uses or processes will be necessary for and related to the purpose for which it was obtained or collected.  PLS will not use or process the data in a manner that is inconsistent with the reason it was collected or authorized to be used.  PLS will take reasonable measures to ensure that the data is accurate, complete, current, and reliable for its intended use.
7.  Enforcement:  PLS is committed to monitoring and ensuring compliance with this policy and relevant privacy laws and regulations.  PLS maintains strict confidentiality and security policies with respect to all data it receives that applies to all of its personnel.  In compliance with the EU-US Privacy Shield Principles, PLS commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union individuals with inquiries or complaints regarding this privacy policy should first contact PLS at:

Porzio Life Services, LLC
100 Southgate Parkway
Morristown, NJ  07962
Attn: Brian P. Sharkey
sharkey@pls.com

PLS has further committed to refer unresolved privacy complaints under the EU-US 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, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Please note that if your complaint is not resolved through the above channels, you may have the right, under certain limited conditions, to invoke binding arbitration before the Privacy Shield Panel to be created by the US Department of Commerce and the European Commission.

PLS is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with respect to its compliance with  the EU-US Privacy Shield.

US-Swiss Safe Harbor

PLS complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland.  PLS has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern.  To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/.

In compliance with the US-Swiss Safe Harbor Principles, PLS commits to resolve complaints about your privacy and our collection or use of your personal information.  Swiss citizens with inquiries or complaints regarding this privacy policy should first contact PLS at:

Porzio Life Services, LLC
100 Southgate Parkway
Morristown, NJ  07962
Attn: Brian P. Sharkey
sharkey@pls.com

PLS  has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism 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, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

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