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Exciting news! ProPharma Group and The Planet Group announce merger.  Learn More
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 * Regulatory Affairs
   
   Expertise at every stage.
   
   DevelopmentClinicalCommercial
   
   Some of the specialized fields we support:
   
   Medical DeviceCell and Gene TherapyData Integrity
   
   OVERVIEW
   
   FDA SERVICES: DRUG DEVELOPMENT
   
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PRIVACY NOTICE

 1.  This Privacy Notice (the “Notice”) sets out how we, ProPharma Group
     Holdings, LLC, a Delaware registered company number FEIN 46-4218037 with
     offices at 8717 W. 110th St, Suite 300, Overland Park, KS 66210, and our
     affiliates, parent companies and associated offices from time to time
     (collectively “ProPharma”, “we”, “us”, “our”) process the personal data of
     individuals (each a “User”, “you”, “your”) who contact us or who use our
     websites, services, applications, content and related features
     (collectively, the “Website”) or whose details we process on behalf of our
     clients in connection with our client services (“Client Services”).
 2.  If you have any questions about this Notice, please contact us by email.
 3.  This notice, together with our Website Terms and any other documents
     referred to in these documents, set out our views and practices regarding
     your personal data and how we will treat it. Please read these documents
     carefully. By visiting our website, you acknowledge the processing
     described in this Notice, our Website Terms and related documents.
 4.  We will let you know, by posting on our website or otherwise, if we make
     any changes to this Notice from time to time. Your continued use of the
     Website, our services or your continued dealing with us after notifying
     such changes will amount to your acknowledgement of the amended Notice.
 5.  This version of our privacy notice was published in December 2017.

     What are personal data?

 6.  “Personal data” means any information relating to an identified or
     identifiable natural person, known as ‘data subject’, who can be identified
     directly or indirectly; it may include name, address, email address, phone
     number, IP address, location data, cookies, a recording of your call with
     us and similar information. It may also include “special categories of
     personal data” such as racial or ethnic origin, political opinions,
     religious or philosophical beliefs, or trade union membership, and the
     processing of genetic data, biometric data for the purpose of uniquely
     identifying a data subject, data concerning health or data concerning a
     natural person’s sex life or sexual orientation.

     What personal data do we process?

 7.  We may process the following personal data:
     * Information provided by you. You may give us information about you by,
       for example, filling in forms such as the contact form on our website,
       subscribing to services, such as email updates, making applications in
       respect of job postings, corresponding with us by e-mail, phone or
       otherwise. This information may include your name, email address, phone
       number, information about your query and similar information.
     * Information about others. You may also provide to us personal data
       relating to third parties, such as people who you work with, or your
       referees. Information about third parties should only be provided if you
       have demonstrable permission to do so or if the information is available
       in the public domain.
     * Information about your device. With regard to each visit to our website
       we may collect technical information about your device such as IP
       address, operating system, browser, time zone setting, the Internet
       address of the website from which you linked directly to our website, URL
       clickstream data, page interaction information (such as scrolling,
       clicks, and mouse-overs), and methods used to browse away from the page.
     * Information from third party sources. This may include information about
       you received from credit reference agencies, our service providers and
       other third parties.
     * Information processed on behalf of our clients. Where we provide Client
       Services to our clients, we will process personal data as a data
       processor on behalf of the client, the data controller. Such processing
       will be in accordance with any privacy notice provided to you by the
       client or by us on the client’s behalf. The processing may include
       interacting with data subjects (via phone, fax or electronically) on
       queries that may be related to Medical Information (MI), an Adverse Event
       (AE) or Product Complaint (PC) or in connection with other Client
       Services from time to time. The information processed may include:
       * MIs: may include a mixture of information set out below.
       * AEs: date of report, reporter name, reporter type (physician,
         pharmacist, nurse, consumer, etc.), patient identifier, patient gender,
         patient age, patient weight/height, demographic information (address,
         city, country/state, phone number), medical history, sexual
         orientation, race, biometric and genetic data, drug (dose, frequency,
         history, action taken following event), event description/outcome, and
         concomitant medications; and
       * PCs: date of report, nature of complaint, lot number, expiration date,
         product retrieval information, and product replacement or reimbursement
         requests.
       * Other: prescription renewal information, reminders to take medication,
         etc.
 8.  Generally, you are under no obligation to provide this information, but
     without it, we may be unable to provide you with some of our Website
     content and services as well as services that we provide on behalf of our
     clients.
 9.  We will rely on the information provided by you as accurate, complete and
     up to date and you agree to ensure that this will be the case.

     Your consent to call recording

 10. We may record telephone conversations. When you call us, we will play a
     short message informing you about call recording, where applicable. You
     will need to follow the instructions as to whether you consent to having
     your call recorded or not.
 11. We may record your calls with us for the following purposes:
     * establishing the existence of facts relevant to our business, including a
       record of your instructions, orders, complaints or other communications;
     * reviewing how we and our personnel comply with our regulatory and legal
       obligations;
     * quality control and staff training;
     * preventing and detecting crime;
     * ensuring the effective operation of our communication systems and
       detecting and preventing unauthorised use; and
     * as otherwise permitted by law.

     How do we use your personal data?

 12. We will only process personal data, in accordance with applicable law, for
     the following purposes:
     * responding to your queries, requests and other communications, for
       example, if you apply for a job or you send us a query about our website;
     * providing the Website and related services including our website, content
       and features;
     * enabling suppliers and service providers to carry out certain functions
       on our behalf in order to provide the Website and related services,
       including webhosting, data storage, identity verification, technical,
       logistical and other functions, as applicable;
     * allowing you to use features on our Website and related services, when
       you choose to do so;
     * carrying out profiling for business administration, recruitment,
       advertising and other business purposes, such as for example analysing
       User trends to deliver relevant ads to Users’ devices; using recruitment
       tools that allow us to score those applicants who complete a test, and to
       consider their suitability for specific roles;
     * sending you personalised marketing communications as permitted by law or
       as requested by you. If you would like to unsubscribe please email us
       here;
     * serving personalised advertising to your devices, based on your interests
       in accordance with our Cookie Statement below. You have the right to
       disable cookies as set out below;
     * ensuring the security of our business and preventing and detecting fraud;
     * administering our business, including complaints resolution,
       troubleshooting of our website, data analysis, quality control, staff
       training, testing of new features, research, statistical and survey
       purposes;
     * developing and improving our Website and related services;
     * providing Client Services, where we process personal data as a data
       processor in accordance with the instructions of our clients in their
       capacity as data controllers; and
     * complying with applicable law, including in response to a lawful request
       from a court or regulatory body.
 13. The legal basis for our processing of personal data for the purposes
     described above will typically include:
     * processing necessary to fulfil a contract that we have in place with you
       or other data subjects, such as  processing for the purposes set out in
       paragraphs 12(a), (b), (c), (d) and (e);
     * your consent, such as processing for the purposes set out in paragraphs
       12(e), (f) and (g);
     * processing necessary for our or a third party’s legitimate interests,
       such as  processing for the purposes set out in paragraphs 12(a), (b),
       (c), (h), (i) and (j), which is carried out on the basis of our
       legitimate interests to ensure that our Website and related services are
       properly provided, ensure the security of our business and our Users and
       the proper administration of our business;
     * processing necessary for compliance with a legal obligation to which we
       are subject, such as processing for the purposes set out in paragraph
       12(l);
     * our agreements with, and instructions provided by, our clients for whom
       we act as a data processor, as set out in paragraph 12(k); and
     * any other applicable legal ground from time to time.

     Cookie Statement

 14. What exactly are cookies? In order to collect the information including
     personal data as described in this Notice, we may use cookies and similar
     technology on our website. A cookie is a small piece of information which
     is sent to your browser and stored on your computer’s hard drive, mobile
     phone or other device. Cookies can be first party, i.e. cookies that the
     website you are visiting places on your device, or third party cookies,
     i.e. cookies placed on your device through the website but by third
     parties, such as, Google. For more information please visit
     www.allaboutcookies.org.
 15. The cookies placed on our website. We use the following cookies on our
     website:
     * Strictly necessary cookies. These cookies are essential in order to
       enable you to move around our website and use its features. Without these
       cookies, the Website and related services you have asked for cannot be
       provided. They are deleted when you close the browser. These are first
       party cookies.
     * Performance cookies. These cookies collect information in an anonymous
       form about how visitors use our website. They allow us to recognise and
       count the number of visitors and to see how visitors move around the
       website when they are using it and the approximate regions that they are
       visiting from. These are first party cookies.
     * Functionality cookies. These cookies allow our website to remember
       choices you make (such as your user name, language or the region you are
       in, if applicable) and provide enhanced, more personal features. The
       information these cookies collect may be anonymised and they cannot track
       your browsing activity on other websites. These are first party cookies.
     * Targeting or advertising cookies. These cookies allow us and our
       advertisers to deliver information more relevant to you and your
       interests. They are also used to limit the number of times you see an
       advertisement as well as to help measure the effectiveness of advertising
       campaigns. They remember that you have visited our website and may help
       us in compiling your profile. These are persistent cookies which will be
       kept on your device until their expiration or earlier manual deletion.
     * Social Media cookies. These cookies allow you to connect with social
       media networks such as Facebook, twitter, LinkedIn and Google+. These are
       persistent cookies which will be kept on your device until their
       expiration or earlier manual deletion.
 16. We may combine information from these types of cookies and technologies
     with information about you from other sources.
 17. Cookie consent and opting out. By using our Website, we assume that you are
     happy for us to place cookies on your device. Most Internet browsers
     automatically accept cookies. However, if you, or another user of your
     device, wish to withdraw your consent at any time, you have the ability to
     accept or decline cookies by modifying your browser setting. If you choose
     to decline cookies, you may not be able to fully experience the interactive
     features of our Website and related services.
 18. You may also opt-out from third party cookies by selecting appropriate
     options on http://www.youronlinechoices.com/uk/.

     Disclosure of personal data

 19. There are circumstances where we may wish to disclose or are compelled to
     disclose your personal data to third parties. These scenarios include
     disclosure to:
     * our affiliates, parent companies or associated offices;
     * our suppliers and service providers to facilitate the provision of the
       Website, related services and our Client Services, including  IT
       consultants, webhosting providers, recruitment services providers,
       identity verification partners (in order to verify your identity against
       public databases), call centres, consultants and similar third parties;
     * subject to appropriate legal basis such as consent, our advertising and
       marketing partners who enable us, for example, to deliver personalised
       ads to your devices or who may contact you by post, email, telephone, SMS
       or by other means;
     * successor or partner legal entities, on a temporary or permanent basis,
       for the purposes of a joint venture, collaboration, financing, sale,
       merger, reorganisation, change of legal form, dissolution or similar
       event relating to our business. In the case of a merger or sale, your
       personal data will be permanently transferred to a successor company;
     * our clients and third parties as directed by our clients, where we
       process personal data as a data processor on behalf of our clients;
     * public authorities, such as law enforcement agencies, courts and other
       public bodies where we are required by law to do so; and
     * other third parties where you have provided your consent.

     International transfer of your personal data

 20. We may transfer your personal data to a third party in countries outside
     the country in which it was originally collected for further processing in
     accordance with the purposes set out above. In particular, your personal
     data may be transferred across our group of companies to the US, Japan and
     other countries. Where this is the case, we will ensure that appropriate
     transfer mechanisms, such as the EU Commission approved Standard
     Contractual Clauses, are in place to ensure an adequate level of data
     protection.
 21. If we transfer personal data to private organisations abroad, such as our
     suppliers and service providers, we will, as required by applicable law,
     ensure that your privacy rights are adequately protected by appropriate
     technical, organisation, contractual or other lawful means. You may contact
     us for a copy of such safeguards in these circumstances.

     Retention of personal data

 22. We retain personal data for as long as is necessary for the purposes listed
     above or longer as may be required by the law. Please contact us for
     further details of applicable retention periods.
 23. We may keep an anonymized form of your personal data, which will no longer
     refer to you, for statistical purposes without time limits, to the extent
     that we have a legitimate and lawful interest in doing so.
 24. We will retain personal data in accordance with our clients’ instructions
     where we act on their behalf as a data processor.

     Security of personal data

 25. We will use appropriate technical and organisational information security
     measures to try to prevent unauthorised access to your personal data.
     However, please be aware that the transmission of information via the
     internet is never completely secure. Whilst we can do our best to keep our
     own systems secure, we cannot control the whole of the internet and we
     cannot therefore guarantee the security of your information as it is
     transmitted to and from our website.
 26. Where you have created or received a password or authentication code which
     enables you to access certain parts of our website, you are responsible for
     keeping this password or authentication code confidential. We ask you not
     to share your password or authentication code with anyone.

     Data subject rights

 27. Depending on your country’s laws, you may have numerous rights in relation
     to your personal data except where we processed such data on behalf of
     another party, e.g. our client as part of Client Services, in which case
     you should contact the client directly in relation to your rights. For
     further information about your data privacy rights please visit the website
     of your local data privacy authority.
     * Right to make a subject access request (SAR). Data subjects may request
       in writing copies of their personal data. However, compliance with such
       requests is subject to certain limitations and exemptions and the rights
       of other individuals. Each request should make clear that a SAR is being
       made. You may also be required to submit a proof of your identity and
       payment, where applicable.
     * Right to rectification. Data subjects may request that we rectify any
       inaccurate or incomplete personal data.
     * Right to withdraw consent. Data subjects may at any time withdraw their
       consent to the processing of their personal data carried out by us on the
       basis of their previous consent. Such withdrawal will not affect the
       lawfulness of processing based on such previous consent.
     * Right to object to processing including profiling. We will comply with
       valid objection requests unless we have a compelling overriding
       legitimate ground for the continuation of our processing or we have
       another lawful reason to refuse such request. We will comply with each
       valid opt-out request in relation to marketing communications.
     * Rights in relation to automated decisions about you. Where we make a
       decision about you based solely on automated processing which
       significantly affects you, you will have you the right to contest the
       decision, express your point of view and obtain human intervention.
     * Right to erasure. Data subjects may request that we erase their personal
       data. We will comply, unless there is a lawful reason for not doing so.
       For example, there may be an overriding legitimate ground for keeping the
       personal data, such as, our business record retention obligations that we
       have to comply with.
     * Restriction. Data subjects may request that we restrict our processing of
       their personal data in various circumstances. We will comply, unless
       there is a lawful reason for not doing so, such as, a legal obligation to
       continue processing your personal data in a certain way.
     * Right to data portability. In certain circumstances, data subjects may
       request the controller to provide a copy of their personal data in a
       structured, commonly used and machine-readable format and have it
       transferred to another provider of the same or similar services. We do
       not consider that this right applies to our Website. However, to the
       extent it does, we will comply with such transfer request. Please note
       that a transfer to another provider does not imply erasure of the data
       subject’s personal data which may still be retained for legitimate and
       lawful purposes.
     * Right to lodge a complaint with the supervisory authority. We suggest
       that data subjects contact us about any questions or complaints in
       relation to how we process their personal data. However, each data
       subject has the right to contact the relevant supervisory authority
       directly. A list of supervisory authorities is available here.
 28. Where we act on behalf of our clients as a data processor, we will pass on
     any rights requests to our respective clients who will then be in touch
     with the requestor.

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Olliver, Aske, Richmond, North Yorkshire, DL10 5HX, UK ProPharma Group MIS
Limited,
Reg No: 03671574, Registered in England and Wales.

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