Privacy Statement

Privacy Information

Global Specimen Solutions, Inc. respects individual privacy and values the confidence of its customers, employees, clinical trial participants, consumers, business partners and others, and strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business on behalf of our clients and upholds the highest ethical standards in its business practices. This Safe Harbor and Privacy Shield Policy Statement (the “Policy”) sets forth the privacy principles Global Specimen Solutions, Inc. follows with respect to transfers of personal information from the European Union (“EU”) and from Switzerland to the United States (“U.S.”).

PRIVACY SHIELD and SAFE HARBOR

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States (the “U.S.-EU Privacy Shield”). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (“FDPIC”) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “U.S.-Swiss Safe Harbor”). Consistent with its commitment to protect personal privacy, Global Specimen Solutions, Inc. adheres to the principles set forth in the U.S.-EU Privacy Shield and the U.S.-Swiss Safe Harbor (the “Privacy Shield and Safe Harbor Principles”).

You can find a list of organizations participating in the Privacy Shield here.

SCOPE

This Policy applies to all personal information received by Global Specimen Solutions, Inc. in the United States from the EU and from Switzerland, in any format, including electronic, paper or verbal that is subject to the U.S.-EU Privacy Shield or the U.S.-Swiss Safe Harbor.

DEFINITIONS

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

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Global Specimen Solutions, Inc. or to which Global Specimen Solutions, Inc. discloses personal information for use on Global Specimen Solutions, Inc.’s behalf.

“Global Specimen Solutions, Inc.” means Global Specimen Solutions, Inc. & Co., Inc., its predecessors, successors, subsidiaries, divisions and groups in the United States.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of Global Specimen Solutions, Inc. to identify an individual. Personal information does not include information that is encoded or anonymized, including key-coded data, or publicly available information that has not been combined with non-public personal information.

“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, Global Specimen Solutions, Inc. 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 have been developed based on the Privacy Shield and Safe Harbor Principles.

NOTICE: Generally, Global Specimen Solutions, Inc. receives only key-coded research data from its clients, which are the data controllers with respect to that data. In the event that Global Specimen Solutions, Inc. collects personal information directly from individuals in the EU or Switzerland and Global Specimen Solutions, Inc. is the data controller, it will inform those individuals about the types of personal information collected, the purposes for which it collects and uses personal information about them, the types of third parties to which Global Specimen Solutions, Inc. discloses that information, the choices and means, if any, Global Specimen Solutions, Inc. offers individuals for limiting the use and disclosure of personal information about them, and how to contact Global Specimen Solutions, Inc. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Global Specimen Solutions, Inc., or as soon as practicable thereafter, and in any event before Global Specimen Solutions, Inc. uses or discloses the information for a purpose other than that for which it was originally collected.

In the event that Global Specimen Solutions, Inc. receives personal information subject to the U.S.-EU Privacy Shield or the U.S.-Swiss Safe Harbor from its clients, subsidiaries, affiliates or other entities that are the data controllers with respect to such information, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: Individuals are entitled to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For sensitive personal information, individuals are entitled to the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

In the event that Global Specimen Solutions, Inc. collects personal information directly from individuals in the EU or Switzerland and Global Specimen Solutions, Inc. is the data controller, Global Specimen Solutions, Inc. will provide individuals with reasonable mechanisms to exercise their choices. If Global Specimen Solutions, Inc. is not the data controller with respect to the personal information, it will take reasonable steps to verify that its clients provide data subjects with requisite choices regarding data processing.

DATA INTEGRITY: Global Specimen Solutions, Inc. will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Global Specimen Solutions, Inc. will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

ACCOUNTABILITY AND ONWARD TRANSFERS: Global Specimen Solutions, Inc. may disclose personal information to third parties such as clients, agents, and public authorities for purposes such as providing services to its clients, responding to legal process or governmental requests, or complying with law. Global Specimen Solutions, Inc. will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Privacy Shield and Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, U.S.-Swiss Safe Harbor or U.S.-EU Privacy Shield certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where Global Specimen Solutions, Inc. has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Global Specimen Solutions, Inc. will take reasonable steps to prevent or stop the use or disclosure. In the event that a Global Specimen Solutions, Inc. agent processes personal information in a manner inconsistent with the principles in the U.S.-EU Privacy Shield, Global Specimen Solutions, Inc. may be held liable for that processing under certain circumstances.

ACCESS AND CORRECTION: Upon request, Global Specimen Solutions, Inc. will grant individuals reasonable access to personal information that it holds about them. In addition, Global Specimen Solutions, Inc. will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete or has been processed in violation of Privacy Shield and Safe Harbor Principles. An individual’s requests to access personal information may be denied under certain circumstances, such as when the individual is participating in a blind study. You may request access to, correction or amendment of, or deletion of personal information by contacting Global Specimen Solutions, Inc. is using the communication channels described in the Contact Information section below. If Global Specimen Solutions, Inc. is not the data controller with respect to the personal information, it will take reasonable steps to help ensure that the controller responsible for enabling individuals to exercise this right responds to the request.

SECURITY: Global Specimen Solutions, Inc. will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: Global Specimen Solutions, Inc. will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Global Specimen Solutions, Inc. determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment. With respect to the U.S.-EU Privacy Shield and the U.S.-Swiss Safe Harbor, Global Specimen Solutions, Inc. is subject to the investigatory and enforcement power of the U.S. Federal Trade Commission.

DISPUTE RESOLUTION: Any questions, concerns, inquiries, or complaints regarding the use or disclosure of personal information subject to the U.S.-EU Privacy Shield or the U.S.-Swiss Safe Harbor should be directed to the Global Specimen Solutions, Inc. Privacy Office using the communication channels described in the Contact Information section below. Global Specimen Solutions, Inc. will investigate and attempt to resolve complaints and disputes by reference to the principles contained in this Policy. For complaints that cannot be resolved between Global Specimen Solutions, Inc. and the complainant, Global Specimen Solutions, Inc. has agreed to participate in the American Arbitration Association (AAA) dispute resolution services. Individuals who submit a question or concern to Global Specimen Solutions, Inc. and who do not receive acknowledgment from Global Specimen Solutions, Inc. of the inquiry or who think their question or concern has not been satisfactorily addressed within 45 days may then contact the AAA Safe Harbor/Privacy Shield Dispute Resolution Program, which is based in the United States. AAA will attempt to resolve these disputes and does not charge individuals a fee for this service. Individuals who think their question or concern has not been satisfactorily addressed by the AAA Safe Harbor/Privacy Shield Dispute Resolution Program may be entitled to invoke binding arbitration under certain circumstances.

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by Global Specimen Solutions, Inc. to these Privacy Shield and Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations (including disclosures of personal information in response to lawful requests by public authorities); and (c) to the extent expressly permitted by an applicable law, rule or regulation.

CONTACT INFORMATION

Questions, comments, inquires, and complaints related to this Policy should be submitted to the Global Specimen Solutions, Inc. Privacy Office by mail to:

Global Specimen Solutions, Inc. Privacy Office
Global Specimen Solutions, Inc.
8601 Six Forks Road, Suite 560
Raleigh, NC 27615

Or by e-mail to the Global Specimen Solutions, Inc. Privacy Office

CHANGES TO THIS POLICY

This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield or Safe Harbor Principles. A notice will be posted on the Global Specimen Solutions, Inc. web page (www.GlobalSpecimen Solutions.com) for 60 days whenever this policy is changed in a material way.

EFFECTIVE DATE: 30December2016