U.S. – E.U. SAFE HARBOR PRIVACY POLICY

We self-certify compliance with:

Safe-Harbor

QPharma, Inc. (“QPharma”) is firmly dedicated assisting pharmaceutical stakeholders, whether pharmaceutical and medical device manufacturers, wholesale distributors, labelers, as well as sales support companies, to understand the regulatory compliance environment that may directly affect their business, and QPharma provides services and resources to such companies in the life sciences industry to help them stay compliant and vigilant with governing law and regulations. Accordingly, QPharma is globally positioned to receive and collect personal information from individuals in the European Union (“EU”) and Switzerland. QPharma has established a robust data privacy program with a strict view towards the protection of your data privacy rights.

QPharma, Inc. (a U.S. company) complies with the U.S.–E.U. Safe Harbor Framework and the U.S.–Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from our subsidiaries, corporate customers, and other business partners in the European Union member countries and Switzerland. QPharma has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.

To learn more about the Safe Harbor program, and to view the certification for QPharma, Inc., please visit http://www.export.gov/safeharbor.

Description of Activities

QPharma anticipates receiving and collecting personal information from individuals in the European Union (“EU”) and Switzerland. QPharma has established a comprehensive privacy program that has been designed to and is intended to protect your data privacy rights.

QPharma adheres to the Safe Harbor Agreement concerning the collection, transfer, and use of personal data from the EU to the United States of America (“US”) and the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce. With respect to such personal information, QPharma follows and adheres to the Safe Harbor Principles published by the U.S. Department of Commerce (“Principles”), and the 15 Frequently Asked Questions concerning all such personal information, including its collection, use, and retention of personal information from EU member countries and Switzerland. 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. Again – to learn more about the Safe Harbor Program and to view our certification page, please visit http://www.export.gov/safeharbor.

  1. Notice: If QPharma collects personal information from individuals in the EU or Switzerland, it will advise them about the purposes for which the information is collected and used, the types of third parties to whom QPharma shares the information, if any, the ability of the users to limit the use and disclosure of such information, and how to contact QPharma. QPharma will provide notice in clear and conspicuous language at the time such information is collected by QPharma or as soon as practicable thereafter and, at all times, before QPharma uses or discloses the information for a purpose other than which it was originally collected. When QPharma receives personal information from other entities in the EU or Switzerland, it will use and disclose such information consistent with the notices provides by such entities and the choices made by the individuals from whom the information was collected.
  2. Choice: QPharma 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, QPharma 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 which it was originally collected or subsequently authorized by the individual.
  3. Onward Transfers: QPharma 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 Privacy Policy and agrees in writing to provide an adequate level of privacy protection.
  4. Access: QPharma will provide individuals with reasonable access to information it has about them upon their request, and QPharma will take reasonable measures to allow for the correction, amendment, or deletion of information that is shown to be incorrect or inaccurate. Regarding this, email QPharma at: jonathan.wright@qpharmacorp.com.
  5. Security: QPharma maintains various safeguards, including physical and electronic and managerial procedures, to protect the security and confidentiality of personal information that it has received. QPharma takes reasonable precautions to protect against unauthorized access, misuse, disclosure, destruction, or alteration of data in its control.
  6. Data Integrity: The personal information uses or processes will be necessary for and related to the purpose for which it was obtained or collected. QPharma will not use or process the data in a manner that is inconsistent with the reason it was collected or authorized to be used. QPharma will take reasonable measure to ensure that the data is accurate, complete, current, and reliable for its intended use.
  7. Information collected by QPharma subsidiaries (if any), corporate customers and business partners.
  8. Enforcement: QPharma is committed to monitoring and ensuring compliance with this policy and relevant privacy laws and regulations. QPharma 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 these policies, and QPharma has procedures in place for personnel to be trained on all of these policies. If an employee fails to adhere to QPharma’s policies, the employee is subject to discipline. QPharma has established a mechanism to conduct reviews of its policies, including their effectiveness and internal compliance with the policies.

 

This Privacy 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-EU and US-Swiss Safe Harbor Principles, QPharma commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact QPharma at: QPharma, Inc. 22 South Street, Morristown NJ 07960, attn: Jonathan Wright, Esq., at jonathan.wright@qpharmacorp.com. Any complaints regarding this Privacy Policy will be investigated, with the goal of resolving the complaint to the satisfaction of all parties.

QPharma has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, JAMS.

Accordingly, if you have any complaints regarding our compliance with the Safe Harbor program, you should first contact us. If the complaint cannot be resolved through our internal dispute resolution process, you may submit your complaint to JAMS for mediation under the JAMS International Mediation Rules, which are accessible on the JAMS website at www.jamsadr.com.

Personal information

QPharma, Inc. may receive personal information from QPharma subsidiaries (if any), our corporate customers, and other business partners in the EEA and Switzerland, such as name, email address, company name, title, postal address, telephone number, and preferences regarding our applications and websites. Any personal information sent to us may be used by QPharma and its subsidiaries and their agents and business partners for the purposes described at the time the information was collected. If you agree to receive email or telephone marketing from us, personal information we receive will also be used for those purposes and for those purposes only. If we plan to use personal information for a purpose that is incompatible with these purposes or if we plan to disclose personal information to a kind of company not described here, we will seek your consent to such uses or disclosures.

Agents and Service Providers

QPharma may work with other companies to help us deliver our services to you on our behalf. These companies may provide services such as offering customer support, processing credit card payments, and sending emails on our behalf. In some cases, these companies will have access to some of your personal information in order to provide services to you on our behalf. They are not permitted to use your information for their own purposes. QPharma requires that any of its agents and service providers that may have access to personal information received by QPharma from the EU or Switzerland subscribe to the Safe Harbor Privacy Principles, be subject to the EU Privacy Directive or another adequacy finding, or enter into a written agreement that requires them to provide at least the same level of privacy protection as is required by the relevant Safe Harbor Principles.