ORIGENT PRIVACY SHIELD POLICY

Effective Date: (2019-04-18)

1. OBJECTIVE

This Privacy Shield Policy (“Policy”) describes how Origent Data Sciences (“Origent”, the “Company”, “we”, “us” and “our”) collect, use, and disclose certain personal data (as defined in the General Data Protection Regulation EU 2016/679) that we receive in the US from the European Economic Area (“Personal Data”). This Policy complements our Website Privacy Policy located at https://origent.com/privacy-policy, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website Privacy Policy.

Origent Data Sciences (“Origent”) complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries transferred to the United States pursuant to Privacy Shield. Origent has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

For purposes of enforcing compliance with the Privacy Shield, Origent is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov. To review Origent’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: https://www.privacyshield.gov/list.

2. POLICY

Personal Data Collection and Use

We may receive the following categories of Personal Data in the US for the following purposes:

Categories of Personal Data:

Origent processes Personal Data that it receives from its customers in the European Union (EU).

Categories of Personal Data include:

  • ORIGENT website visitors’ name, organization, IP address, job title, employment history, and email address;
  • ORIGENT customers’, vendors’, business partners’ professional contact details such as name, title, address, phone number, fax number, and email address;
  • Pseudonymized patient health data such as pulse, respiratory rate, temperature, systolic and diastolic blood pressure, weight, sex, and height.

Purposes of processing:

The Personal Data is processed by Origent in order to:

(1) operate its website and provide products and services;

(2) perform customer and user support activities, such as developing new products and services, provide technical support, and improve product offerings;

(3) perform sales and marketing activities as permissible under applicable law; and

(4) conduct internal business activities such as management of internal IT activities, other internal processes, such as financial processing and management, and compliance with the law.

When Origent is providing services to its business customers, Origent may receive and process Pseudonymized Personal Data as a data processor.

As a data processor, Origent acts on the instructions from its business customers and DOES NOT control the Pseudonymized Personal Data it processes. In some cases, and as permitted by our customer agreements, we may disclose Pseudonymized Personal Data with a subcontractor who is contracted to provide services on our behalf, in order to provide the services to our business customers.

Whenever Origent gives access or transfers Personal Data to a third party, Origent conducts screening activities of such third parties and ensures that appropriate safeguards (organizational and technical) are in place.

Origent will only process Personal Data in ways that are compatible with the purpose that Origent collected it for, or for purposes the individual later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. Origent maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current. If you would like to exercise this right, please contact us at help@origent.com. In the event that we collect sensitive personal data, we will provide an opt-in choice before we use it for a purpose other than which it was originally collected or subsequently authorized.

Data Transfers to Third Parties

Third-Party Agents or Service Providers

We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf as described above, such as third party technology service providers that Origent engages to provide (i) security, storage, verification, hosting, and other managed services in relation with Origent products/services, (ii) IT management, accounting, HR and finance management services. We ensure that those third-party agents and service providers provide the same level of protection Privacy Shield requires and limit their use of the Personal Data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents. If you would like to exercise this choice, please contact us at help@origent.com.

Origent remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Origent proves that it is not responsible for the event giving rise to the damage.

Disclosures for National Security or Law Enforcement

Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security

Origent maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

Access Rights

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is not possible (e.g. pseudonymized Personal Data received from data controllers), unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

Questions or Complaints

In compliance with the Privacy Shield Principles, Origent commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Origent at:

help@origent.com

Origent has further committed to refer unresolved Privacy Shield complaints to the BBB EU PRIVACY SHIELD, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. The services of  BBB EU PRIVACY SHIELD are provided free of charge to you.

Binding Arbitration

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

3. ADMINISTRATION AND REVISIONS

Administration

If you have any questions about this Policy or would like to request access to your Personal Data, please contact us as follows: help@origent.com.

Revisions

We reserve the right to amend this Policy from time to time consistent with the Privacy Shield’s requirements.

4. VIOLATIONS

Violations may result in disciplinary action in accordance with company policy. Violations of, or failure to observe these guidelines may result in disciplinary action by the company up to and including termination, and/or civil or criminal penalties in accordance with applicable laws and regulations.

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