DIRECT SERVICES PRIVACY POLICY

Direct Services respects your privacy. Any personal information you provide to us, including your name, address, telephone number and e-mail address, will not be released, sold or rented to any entities or individuals outside of Direct Services or authorized Direct Services partners and resellers. Direct Services, or one of our authorized partners or resellers, may contact you in regards to Direct Services products or related services. Direct Services customers may receive information regarding special Direct Services events, press releases, news of complementary technologies from our strategic partners and/or product-specific technical information, including security bulletins and notifications of software patches and upgrades.

Direct Services also collects and analyzes visitor information as part of its standard web site activity logging process. This information includes the host domain of the visitor, the pages accessed, the time spent on our site and general browser statistics. No personal information, such as your name or email address, is collected in these web logs. This data enables us to become more familiar with the types of users who visit our site, how often they visit and what parts of the site they visit most often. Direct Services uses this information to improve its products and services. This information is collected automatically and requires no action on your part.

The Direct Services Web site may contain links to Web pages not authored and/or owned by Direct Services. We make no guarantees or promises about the information on those web sites and cannot accept responsibility for the actions or inaction of their operators.

To be removed from our mailing lists:

• At any time you may request to be removed from our electronic mailing list via an e-mail to: postmaster@directservices.com.

• If you would like to be removed from our regular mailing list, please contact the Direct Services Postmaster via e-mail at postmaster@directservices.com, or mail your request to:

Direct Services
14505 Commerce Way, Suite 550
Miami Lakes, FL 33016

The Direct Services Privacy Policy is subject to change without notice.


SAFE HARBOR PRIVACY POLICY


Data Protection at Direct Services

Direct Services respects individual privacy and values the confidence of its customers, employees, clinical trial participants, healthcare professionals, consumers, business partners, investors, and others. Not only does Direct Services strive to collect, use, and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. For these reasons, Direct Services has developed a comprehensive, global privacy program designed to respect and protect the data privacy rights of every person with whom we transact business.

Direct Services intends that its corporate privacy policy and standard practices and procedures will ensure timely compliance with applicable local and international laws and regulations.

This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that Direct Services follows with respect to transfers of personal information from the member states of the European Union (EU) to the United States (US).

• For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s website at http://www.export.gov/safeharbor

Scope

This Policy applies to all personal information received by Direct Services in the US from a member state of the EU in any format including electronic, paper, or verbal. This policy sets certain minimum standards within Direct Services which may be subjected to more stringent privacy safeguards as a result of the requirements of GCP, ICH, or other national and international requirements.

Definitions


For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that uses personal information provided by Direct Services to perform tasks on behalf of and under the instructions of PRA.

"Direct Services" means Direct Services, its predecessors, successors, subsidiaries, divisions and groups in the United States.

"Personal information" means any information or set of information that identifies or could be used by or on behalf of Direct Services to identify an individual. Personal information does not include information that is encoded or stripped of all personal identifiable information, or which is publicly available.

"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns the health or sex life of an individual. In addition, Direct Services will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

Privacy Principles

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

NOTICE: Where Direct Services collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses the information, the types of third parties to which Direct Services discloses that information, and the choices and means, if any, Direct Services offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to PRA, or as soon as practicable thereafter, and in any event before Direct Services uses the information for a purpose other than that for which it was originally collected.

Where Direct Services receives personal information from its subsidiaries, affiliates or other entities in the EU, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: Direct Services will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, Direct Services will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a third party or to the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Direct Services will provide individuals with reasonable mechanisms to exercise their choices.

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

TRANSFERS TO AGENTS: Direct Services may share an individual's information with agents, contractors or partners of Direct Services in connection with services that these individuals or entities perform for, or with, PRA. Direct Services may, for example, provide an individual's personal information to contractors or business partners for hosting our databases, for data processing services, or to send to that individual the information that he or she requested.

Direct Services will obtain assurances from its agents and contractors that they will safeguard personal information received from us in a manner consistent with this Policy. Appropriate assurance of compliance may be given in a number of ways, which may include one or more of the following:

1. A contract between Direct Services and the third party which includes provisions obligating the third party to provide at least the same level of protection as is required by the relevant Safe Harbor Principles.
2. The third party may be, subject to the EU Data Protection Directive itself.
3. The third party may have filed its own Safe Harbor certification.
4. The third party may have Binding Corporate Rules approved by the European Commission, or may be subject to another European Commission adequacy finding (e.g. Argentina, Canada, Guernsey, Hungary, Isle of Mann, Switzerland).

Where Direct Services has knowledge that an agent, contractor or partner is using or disclosing personal information in a manner contrary to this Policy, Direct Services will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, individuals will be granted reasonable access to personal information that Direct Services holds about them. In addition, upon request, Direct Services will take reasonable steps to permit individuals to correct, amend, or delete information that is found to be inaccurate or incomplete.

SECURITY: Direct Services will employ reasonable safeguards to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. For personal information subject to electronic storage or transmission, Direct Services maintains an internal private, secure global network that is protected from computer virus infection and monitored for unauthorized access. Both electronic and paper based records holding personal information are maintained in access controlled facilities for which business continuity plans are required.

ENFORCEMENT: Direct Services will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy.

All reported breaches or potential breaches will be investigated by the Privacy Officer(s) and the investigative agents the Officer assigns, who will take such actions as they deem appropriate in the investigation and if necessary, remediation of the situation. Any employee that Direct Services determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment. In the event of criminal or other serious violations of the law, these actions could also be subject to notification of the appropriate legal body.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Privacy Officer at the address given below. Direct Services 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.

CONTACT INFORMATION: Questions or comments regarding this Policy should be submitted to the Direct Services Privacy Office by mail to:

Direct Services
C/O Privacy Officer
14505 Commerce Way, Suite 550
Miami Lakes, FL 33016

PrivacyOfficer@directservices.com

If you feel that Direct Services may not have abided by the US – EU Safe Harbor privacy principles, you may contact Direct Services at the address above, or the US Federal Trade Commission.

RESERVATION OF RIGHTS: Direct Services reserves the right to share an individual's information as required by law or to duly authorized information requests of government authorities.

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. Appropriate public notice will be given concerning such amendments.

© 2017 Direct Services