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Safe Harbor Privacy Policy

Data Protection at Anaclim

Scope

Anaclim’s privacy policy defines the process for protecting the privacy of those who entrust Anaclim with their personal information during the conduct of clinical research. This policy applies to all personal information, either in electronic, paper, or verbal format, received by Anaclim in the United States from the European Union nations. Anaclim adheres to the Safe Harbor Policy principles as agreed to by the U.S. Department of Commerce and European Commission.

For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s website at http://www.export.gov/safeharbor.

Definitions

For purposes of this policy, the following definitions shall apply:

“Agent” is a third party that processes personal data on behalf of and under the instruction of Anaclim.

“Personal Information” is any information or set of information that identifies or could be used by or on behalf of Anaclim 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” is any personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, Anaclim will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

Privacy Principles

The privacy principles in this policy are based on the Safe Harbor Privacy Principles

Notice: Where Anaclim collects personal information from individuals in the European Union it will inform them about the purposes for which we collect and use personal data about them, how to contact us, the types of non-agent third parties with whom we may share personal data, and any ways that individuals may limit the use and sharing of such data.

Choice: Anaclim will offer an individual the opportunity to choose (opt out) whether their personal information are (a) disclosed to a third party or (b) used for a purpose other than that for which the information was originally collected or subsequently authorized by the individual.
For sensitive personal information, Anaclim will give an individual an affirmative or explicit (opt in) choice if the information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected or subsequently authorized by they individual.

Onward Transfer: Upon request, Anaclim will provide individuals with reasonable access to information with agents, contractors or partners of Anaclim in connection with services that these individuals or entities perform for, or with, Anaclim. Anaclim will obtain assurances from its agents that they will safeguard personal information consistently with this policy.

Access: Upon request Anaclim will provide individuals with reasonable access to personal information about them. Individuals may request their information to be corrected, amended, or deleted where it is found to be inaccurate.

Security: Anaclim will take reasonable precautions to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Data Integrity: Personal information obtained by Anaclim will only be used in ways that that are consistent with purposes for which it was collected. Anaclim will take reasonable steps to ensure that data is reliable for its intended use, accurate, complete, and current.

Enforcement: Anaclim’s Privacy Officer will ensure the ongoing adherence to this policy by authorizing and/or conducting objective reviews.

Questions about this policy: Questions regarding this policy should be addressed to the Anaclim Privacy Officer at Anaclim, LLC, c/o Privacy Officer, 6325 Digital Way, Suite 401, Indianapolis, Indiana, 46278.
In order to investigate unresolved complaints regarding this policy, Anaclim has chosen to utilize an outside arbitration and mediation service.

Changes to this Safe Harbor Privacy Policy: This policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Appropriate public notice will be given concerning amendments.