Safe Harbor Policy

Last updated on September 29, 2016

MedPro Systems LLC (“MedPro”) is dedicated to helping members of the pharmaceutical and medical device industries understand the regulatory environment that impacts their business, and it provides services and resources to companies in the life sciences industry to help them stay compliant with governing law. MedPro anticipates receiving and collecting personal information regarding individuals in Switzerland. This Safe Harbor Policy describes MedPro’s practices only with respect to information regarding Swiss individuals. Individuals in the European Union are directed to MedPro’s Privacy Shield Policy and all other individuals are directed to MedPro’s Privacy Policy.

MedPro adheres to the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce. With respect to personal information regarding Swiss individuals that is received by MedPro, MedPro follows and adheres to the Safe Harbor Principles published by the U.S. Department of Commerce (“Principles”), including its collection, use, and retention of personal information regarding Swiss individuals. The Principles are: Notice, Choice, Onward Transfers, Access, Security, Data Integrity, and Enforcement. The terms “personal information,” “information,” and “sensitive personal information” as used herein have the same meaning as used defined in the Safe Harbor Program. To learn more about the Safe Harbor Program and to view our certification page, please visit http://www.export.gov/safeharbor.

If there is any conflict between the policies in this Safe Harbor Policy and the Safe Harbor Principles, the Safe Harbor Principles shall govern.

  1. Notice: If MedPro collects personal information from individuals in Switzerland, it will advise them about the purposes for which the information is collected and used, the types of third parties to whom MedPro shares the information, if any, the ability of the users to limit the use and disclosure of such information, and how to contact MedPro. MedPro will provide such notice in clear and conspicuous language at the time such information is collected by MedPro or as soon as practicable thereafter and, at all times, before MedPro uses or discloses the information for a purpose other than which it was originally collected. When MedPro receives personal information from other entitles in Switzerland, it will use and disclose such information consistent with the notices provides by such entitles and the choices made by the individuals from whom the information was collected.
  2. Choice: MedPro will provide individuals with the choice of whether the personal information is to be disclosed to a non-agent third party or used for a purpose other than that for which it was originally collected or subsequently authorized by the individual. For sensitive personal information, MedPro will provide individuals with the opportunity to affirmatively or explicitly consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than that for which it was originally collected or subsequently authorized by the individual.
  3. Onward Transfers: MedPro will not disclose personal information to third parties unless such disclosure is permissible pursuant to applicable law and regulations and only if the third party operates in a manner pursuant to this policy and/or the Safe Harbor Agreements and Principles and provides the same level and degree of privacy protection as established in this Safe Harbor Policy and agrees in writing to provide an adequate level of privacy protection.
  4. Access: MedPro will provide individuals with reasonable access to information it has about them upon their request, and MedPro will take reasonable measures to allow for the correction, amendment, or deletion of information that is shown to be incorrect or inaccurate.
  5. Security: MedPro maintains various safeguards, including physical and electronic and managerial procedures, to protect the security and confidentiality of personal information that it has received. MedPro takes reasonable precautions to protect against unauthorized access, misuse, disclosure, destruction, or alteration of data in its control.
  6. Data Integrity: The personal information MedPro uses or processes will be necessary for and related to the purpose for which it was obtained or collected. MedPro will not use or process the data in a manner that is inconsistent with the reason it was collected or authorized to be used. MedPro will take reasonable measures to ensure that the data is accurate, complete, current, and reliable for its intended use.
  7. Enforcement: MedPro is committed to monitoring and ensuring compliance with this policy and relevant privacy laws and regulations. MedPro maintains strict confidentiality and security policies with respect to all information it receives that applies to all of its personnel. All personnel are made aware of the policies, and MedPro has procedures in place for personnel to be trained on all of the policies. If an employee fails to adhere to MedPro’s policies, the employee is subject to discipline. MedPro has established a mechanism to conduct reviews of its policies, including their effectiveness and internal compliance with the policies.

This Safe Harbor Policy may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy online on this website.

In compliance with the US-Swiss Safe Harbor Principles, MedPro commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss individuals with inquiries or complaints regarding this Safe Harbor Policy should first contact MedPro at:

MedPro Systems LLC
100 Stierli Court
Mt. Arlington, NJ 07856
Attention: Bryan Andrews – Director, Sales Operations
mailto:safeharbor@medprosystems.com

Any complaints regarding this Safe Harbor Policy will be investigated, with the goal of resolving the complaint to the satisfaction of all parties.

MedPro has further committed to refer unresolved privacy complaints under the US Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by MedPro, please visit the BBB SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaintsfor more information and to file a complaint.

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