Effective 9 September 2016
For the purposes of this policy:
“EEA” means the European Economic Area;
“Envision Pharma Group”/“we”/“us”/“our” means Envision Pharma Holdco Limited and its group companies (including, without limitation, Envision Pharma Inc., Envision Pharma Limited and ProScribe Pty Ltd) as applicable;
“Personal Information” means any information or 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 race; ethnic origin; sexual orientation; health; genetics; biometrics; political, philosophical or religious beliefs; trade union membership; membership of a professional or trade association; or criminal records;
“Website” means www.envisionpharmagroup.com.
IMPORTANT: BY PROVIDING PERSONAL DATA TO US AND/OR BY USING THE WEBSITE YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA YOU PROVIDE MAY BE COLLECTED, USED AND DISCLOSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED BELOW.
Envision Pharma Group complies with all applicable data protection and privacy laws including, without limitation, the UK Data Protection Act 1998 and the Australian Privacy Act 1988 (Cth).
Envision Pharma Group complies with the principles of the US-EU Privacy Shield Framework regarding the transfer of Personal Information from the EEA 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 www.privacyshield.gov.
In addition, Envision Pharma Group complies with the principles of the US-Swiss Safe Harbor Framework regarding the transfer of Personal Information from Switzerland to the United States. Envision Pharma Group has certified compliance with the US-Swiss Safe Harbour. To view our certification, please visit http://2016.export.gov/safeharbor/.
Envision Pharma Group provides a range of scientific communications services to our clients, including the provision of hosted software applications. As part of providing these services and operating our business, we will typically be provided with names, addresses, email addresses and other contact information of our clients and their employees, suppliers and certain other third parties (such as authors or physicians).
In addition, we may collect similar Personal Information from individuals applying for vacant job roles within our organization.
Sometimes personal information is not sought by us but is delivered or sent to us without prior request. Where unsolicited information is received by us, we will, within a reasonable period, determine whether that information is directly related to one or more of our functions or activities. If this cannot be determined, we will, as soon as practicable, destroy or de-identify the information. If this can be determined we will notify you of the purpose of collection and our intended uses and disclosures, unless it is impracticable or unreasonable for us to do so.
You may wish to remain anonymous, or use a pseudonym when interacting with us but it is likely this will make it impractical for us to deal with you.
The collection of Personal Information shall be lawful and fair; limited to that which is relevant; and shall not be excessive.
Personal Information may be used by us for the following:
- To provide services to our clients, including the handling of Personal Information of others on behalf of our clients
- To market our services
- To manage our relationship with our clients and potential clients
- For the purposes of recruitment
- To provide and improve the Website
- To compile anonymous statistics
- For other legitimate business purposes.
Any Personal Information that individuals provide will be used by Envision Pharma Group lawfully; in an appropriate manner; only for the purposes of fulfilling the specific purpose for which it was obtained; and in accordance with the individual’s legal rights.
Envision Pharma Group will not share this personal information with any third party, except as stated below, without the consent of the individual.
Personal Information may be shared between group companies within Envision Pharma Group for the purposes of providing our services or other legitimate business reasons.
The foregoing group companies and contractors may be based in countries outside of your location (including the EU, USA, Australia and Japan) and thus Personal Information may be sent to the countries in which they are located.
Envision Pharma Group may release Personal Information to third parties without user consent: (1) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena, court order or lawful requests by public authorities, including regarding national security or law enforcement purposes; or (2) in special cases, such as in response to a physical threat, to protect property, or defend or assert legal rights. In the event that Envision Pharma Group is legally compelled to disclose Personal Information to a third party, Envision Pharma Group will attempt to notify the relevant individual unless doing so would violate the law or court order.
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.
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.
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.
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.
For complaints regarding the US-EU Privacy Shield principles or the US-Swiss Safe Harbor 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) and Swiss Federal Data Protection and Information Commissioner (FDPIC) 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 or the US Swiss Safe Harbor Principles (as applicable).
Regarding the US-EU 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.
Questions or comments regarding this Policy should be submitted to Envision Pharma Group as follows:Envision Pharma Group
FAO: General Counsel
26-28 Hammersmith Grove
W6 7HA, United Kingdom
Tel: +44 (0) 208 834 3930