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”), the United Kingdom, and Switzerland 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, the United Kingdom, and Switzerland 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.
1. Notice: When PLS directly collects personal information from EU, British, and/or Swiss individuals, as explained below, it 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, British, and Swiss 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 such 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, except as provided herein. 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. and Swiss-U.S. Privacy Shield Frameworks 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 at the 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 and that such third-party will notify Porzio if it makes a determination that it can no longer meet this obligation. 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 personal information with non-agent third parties.
PLS may disclose personal information to the following types of organizations:
We may transfer your personal data outside the European Economic Area (“EEA”). To ensure a degree of protection similar to that within the EEA, we will only transfer your personal data:
To countries that have been deemed to provide an adequate level of protection for personal data by the European Commission, or
In cases of onward transfers to third parties of personal information of EU, British, and/or Swiss individuals received pursuant to the Privacy Shield, PLS is potentially liable if the third party processes such personal information in a manner inconsistent with the Privacy Shield, unless PLS proves that it is not responsible for the event giving rise to the damage.
4. Access: PLS acknowledges that EU, British, and Swiss 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, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated.. 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 loss, misuse and unauthorized access, disclosure, alteration and destruction of data in its control, taking into due account the risks involved in the processing and the nature of the personal data.
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.
Porzio Life Services, LLC
100 Southgate Parkway, Morristown, NJ 07962
Attn: Steven P. Benenson
PLS has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
PLS is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Last revised: February 22, 2021.
Effective date: October 1, 2021.