Safe Harbor Privacy Policy

United BioSource Corporation (“UBC”) respects individual privacy and is committed to maintaining the privacy and security of the personal information of our customers, employees, business partners and others with whom we interact. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles that UBC follows with respect to transfers of personal information between member states of the European Economic Area (“EEA”) and the United States, and Switzerland and the United States.

SCOPE

This Policy applies to all personal information received by UBC in the United States from the EEA and/or Switzerland in any format including electronic or hard copy.

DEFINITIONS

“United BioSource Corporation” means United BioSource Corporation and any of its subsidiaries, divisions, successors and assigns.

“Personal information” means any information or set of information that identifies or is used by or on behalf of UBC to identify an individual. Personal information does not include information that is encoded or anonymized, 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 or religious beliefs or personal information regarding health conditions.

PRIVACY PRINCIPLES

The privacy principles in this policy are based on the Safe Harbor Principles.

NOTICE

When UBC directly collects personal information from individuals in the EEA, it will (1) disclose the purpose for collecting and using the personal information, (2) describe the types of entities to whom disclosures may be made, (3) describe the choices and means, if any, offered by UBC to individuals to limit the use and disclosure of information and (4) provide contact information to individuals where their inquiries or complaints can be addressed. Notice will be provided at the time when individuals are first asked to provide personal information or as soon as practicable.

CHOICE

UBC will offer individuals the opportunity to opt-out of further uses or disclosures when their personal information will be disclosed to a non-agent third party or in connection with a purpose other than the purposes for which it was originally collected or authorized by the individual. If the use or disclosure involves sensitive information, UBC affords individuals the opportunity to explicitly opt-in to such use or disclosure when the sensitive information would be disclosed to a non-agent third party or in connection with a purpose other than the purposes for which it was originally collected or authorized by the individual.

DATA INTEGRITY

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

TRANSFERS TO AGENTS

UBC will obtain adequate assurances from its agents and other business partners that they will safeguard personal information in a manner consistent with this policy.

ACCESS AND CORRECTION

UBC will grant individuals reasonable access to personal information that it holds about them, unless such access would compromise the purpose for which it was collected such as blinded clinical research data during the trial. UBC will take reasonable steps to assist individuals with correcting, amending or deleting personal information that is determined to be inaccurate or incomplete.

SECURITY

UBC will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT

UBC will verify its adherence to this Policy by conducting routine compliance audits of its relevant privacy practices. UBC will take appropriate disciplinary action, consistent with applicable laws, against any UBC employee who willfully violates or seeks to circumvent this Policy or who takes an action to compromise the integrity or safety of personal data.

DISPUTE RESOLUTION

Any questions or concerns regarding the use or disclosure of personal information should be directed to the UBC Corporate Office at the address given below. UBC will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between UBC and the complainant, UBC has agreed to participate in the dispute resolution procedures of the panels established by the European data protection authorities and the Federal Data Protection and Information Commissioner of Switzerland to resolve disputes pursuant to the Safe Harbor Principles.

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by UBC to these Safe Harbor Principles may be limited to the extent (1) required to respond to a legal or ethical obligation, or (2) expressly permitted by an applicable law, rule or regulation, such as processing data specifically requested by government agencies for the purpose of medical safety.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the UBC Corporate Office by mail as follows:

United BioSource Corporation
4445 Willard Avenue
12th Floor
Chevy Chase, MD 20815
Tel: +1 866 458 1096
Fax: +1 240 644 0421
privacy@unitedbiosource.com

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. UBC will undertake annual self-certification in compliance with the Safe Harbor requirements for continued registration.