SCOPE: This Policy applies to all Personal Information of Individuals, either in electronic or paper format, received by CENTUVA, including Personal Information of Company Personnel, consumers, healthcare professionals, patients, medical research subjects, clinical investigators, customers, suppliers, vendors, business partners and investors.
DEFINITIONS: For purposes of this Policy, the following definitions shall apply:
“Sensitive Personal Information” means Personal Information that reveals or is processed to uniquely identify a person:
Where CENTUVA collects Personal Information directly from Individuals, it will explain the purposes for which it collects and uses Personal Information about the Individuals, the types of third parties to which CENTUVA discloses that information, and the choices and means, if any, CENTUVA offers Individuals options for limiting the use and disclosure of Personal Information about them. This explanation will be provided as soon as practicable and, in any event, before CENTUVA discloses the Personal Information or uses such information for a purpose materially different than that for which it was originally collected or processed. CENTUVA also will provide any additional information required by law for a specific context, product or service. In general, with exceptions and other lawful bases that may be relevant for any specific product or service notice, CENTUVA processes personal data for its legitimate interests consistent with applicable law. Where an CENTUVA entity receives Personal Information from another CENTUVA entity or other entities, including when acting as a CRO processing Personal Information under the direction of a customer, it will use such information in accordance with the notices provided by such entities and the choices made by the Individuals to whom such Personal Information relates.
Types of Personal Information collected, Purposes of Collection and Uses of Personal Information:
CENTUVA may also use the Personal Information collected above to comply with our legal and regulatory obligations, policies and procedures, and for internal administrative purposes.
CENTUVA may offer Individuals the opportunity to choose whether their Personal Information is (a) to be disclosed to a third party, or (b) to be used for a purpose materially different from the purpose for which it was originally collected or subsequently authorized by the Individual.
CENTUVA will not process Sensitive Personal Information about Individuals for purposes other than those for which the information was originally obtained or subsequently authorized by the Individual unless the Individual explicitly consents to the processing (“opt-in”), or as required or permitted, or where not prohibited by law or regulation.
In some cases, even if an Individual opts-out of disclosures of their Personal Information, CENTUVA may still disclose such Personal Information (i) if required to do so by law, (ii) if disclosure is required to be made to law enforcement authorities, or (iii) if we believe disclosure is necessary or appropriate to prevent physical harm to an individual or financial loss or in connection with an investigation of suspected or actual illegal activity. CENTUVA also may transfer Personal Information when a material event concerning its business operation(s), assets or shares, such as purchase, disposal, merger, joint venture or acquisition, is proposed or occurs. In such an event, CENTUVA will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Policy. CENTUVA will provide Individuals with reasonable mechanisms to exercise their choices to the extent required by applicable law.
In the performance of our services and business operations, Personal Information we collect or receive may be stored or transferred internationally throughout our organization and to our service providers or agents, including for hosting our databases or provision of data processing services, in accordance with applicable data privacy laws. Transfers to third parties are covered by the provisions in this Policy regarding notice and choice.
CENTUVA may also share an Individual’s Personal Information with Agents in connection with services that these individuals or entities perform for, or with, CENTUVA. CENTUVA may, for example, provide an Individual’s Personal Information to Agents for hosting our databases, for data processing services, or to send to that Individual the information that he or she requested.
CENTUVA may transfer Personal Information for specified, limited purposes, to an Agent and will endeavor to obtain assurances that such Agent provides at least the same level of privacy protection as is required by the Privacy Shield Principles (where applicable) and this Policy and will notify CENTUVA if it makes a determination it can no longer meet this obligation.
Where CENTUVA knows that any third party to whom it has provided Personal Information is using or disclosing Personal Information in a manner contrary to this Policy, CENTUVA will take reasonable steps to prevent or stop the use or disclosure. With respect to such onward transfers to Agents, and to the extent CENTUVA is responsible for the event, CENTUVA shall remain liable should its Agents process Personal Information in a manner inconsistent with the Privacy Shield Principles (where applicable) and this Policy.
CENTUVA will employ reasonable and appropriate technical, administrative and physical safeguards designed to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Information CENTUVA is processing. We have a privacy incident response program designed to promptly respond to and escalate all privacy-related questions, complaints, concerns, including any potential privacy or security incident.
CENTUVA endeavors to use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the Individual. CENTUVA will take reasonable steps designed to ensure that only Personal Information that is relevant to its intended use, accurate, complete, current, and otherwise reliable in relation to the purposes for which the information was obtained is used by CENTUVA for as long as CENTUVA retains possession of such information. CENTUVA’s Personnel have a responsibility to assist CENTUVA in maintaining accurate, complete and current Personal Information. When acting as a CRO, CENTUVA endeavors only to process Personal Information that is relevant to the services it provides, and for purposes compatible with those for which the Personal Information was collected; wherever possible, such Personal Information is non-identified. Where CENTUVA processes Personal Information as a CRO under the direction of its customers, CENTUVA works with such customers so that the customers can provide a way for Individuals to correct or update their Personal Information to the extent required by law.
Under laws in certain countries in which we operate, individuals have a right to access Personal Information about themselves, and to amend, correct or delete Personal Information that is inaccurate, incomplete or outdated. CENTUVA will, on request, provide an Individual with confirmation regarding whether CENTUVA is processing Personal Information about them, consistent with applicable law. In addition, upon request of an Individual, CENTUVA may take reasonable steps to correct, amend, or delete their Personal Information that is found to be inaccurate, incomplete or processed in a manner non-compliant with this Policy or applicable law, except where the burden or expense of providing access would be disproportionate to the risks to that Individual’s privacy, where the rights of persons other than the Individual would be violated or where doing so is otherwise inconsistent with applicable law. Unless prohibited by applicable law, CENTUVA reserves the right to charge a reasonable fee to cover costs for providing copies of Personal Information requested by Individuals. CENTUVA, when acting as a CRO, has no direct relationship with medical research subjects participating in a clinical trial and any such Individuals who seek access, or who seek to correct, amend, or delete their inaccurate Personal Information should direct his or her query to the relevant study sponsor or investigator which has transferred such Personal Information to CENTUVA for processing.
Although CENTUVA makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which CENTUVA is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If CENTUVA determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, CENTUVA will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
Where otherwise permitted by applicable law, you may send an e-mail to email@example.com to request access to, receive, seek rectification, or request erasure of Personal Information held about you by CENTUVA. Such requests will be processed in line with local laws.
CENTUVA encourages Individuals covered by this Policy to raise questions about the processing of Personal Information about them by contacting CENTUVA through the contact information provided below. Any Personnel that CENTUVA determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment, where applicable.
Any questions or concerns regarding the use or disclosure of Personal Information should also be directed to CENTUVA through the contact information given below. CENTUVA will undertake reasonable efforts to investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy.
If you are an EU or Swiss citizen and feel that CENTUVA is not abiding by the terms of this Policy, please contact CENTUVA at the contact information provided below. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.
In certain circumstances, CENTUVA has agreed to cooperate with the American Arbitration Association (“AAA”) with respect to complaints of Individuals that are not Personnel of the Company and with the local data protection authorities with respect to Personnel and human resources related information consistent with applicable law. Such independent dispute resolution mechanisms are available to Individuals free of charge.
CONTACT INFORMATION: Questions, comments, concerns or complaints regarding this Policy or CENTUVA’s processing of Personal Information should be submitted to CENTUVA at firstname.lastname@example.org
RESERVATION OF RIGHTS: CENTUVA reserves the right to share an Individual’s Personal Information and contracts with Agents as required or authorized by law or regulation or in response to duly authorized information requests of government authorities.
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