Privacy Policy

As a premier boutique marketing agency leading the way in direct-to-patient and word-of-mouth
initiatives for the Pharma, Biotech, and Medical Device industries, Snow Companies, Inc.
(“Snow”), understands the importance of privacy. At Snow, we consider the privacy of our
clients and our patient ambassadors a serious matter. Individuals who provide any personal
information, including personal health information, to Snow should review this Privacy Policy
before doing so. The submission of personal information to Snow constitutes consent to the
terms of this Privacy Policy.

Snow receives personal and health-related information from patient ambassadors and individuals
who nominate themselves to be patient ambassadors. All information collected by Snow is
provided voluntarily by the individual through the submission of surveys and/or questionnaires,
and by participation in interviews conducted by Snow personnel, or individuals acting on behalf
of Snow. The personal information collected by Snow may include name, contact information
(both physical and electronic), date of birth, social security number, family information,
photographic image, and personal health information (collectively referred to as “Collected

Collected Data is only used in connection with the individual’s relationship with Snow. For
patient ambassadors, Collected Data is used by Snow for the effective management of the patient
ambassador relationship, including business communications, training, and payment of
honoraria. For all others who voluntarily submit Collected Data to Snow, the Collected Data is
used to determine potential patient ambassador opportunities for those who have requested
consideration for such opportunities. Snow does not transfer, sell, rent, or lease any Collected
Data to others unless required by law or your prior permission is obtained.

Individuals may have reasonable access to their Collected Data to correct, amend or delete
information that is inaccurate. Snow may require an individual to provide acceptable proof of
identity prior to granting reasonable access. Requests for access should be directed to, or Robin Branscome, Privacy Officer, Snow Companies, Inc., 219
Bulifants Blvd., Williamsburg, VA 23188, Telephone: 757-345-6480.

Snow enforces strict security and data integrity measures to protect the privacy of all Collected
Data. Snow upholds internal policies and practices to protect Collected Data from loss, misuse
and unauthorized access, disclosure, alteration and destruction. Snow will take reasonable steps
to ensure that Collected Data is reliable for its intended use, accurate, complete, and current.
Any questions or complaints regarding Collected Data should be directed to Snow’s Privacy
Officer, Robin Branscome, at, or 757-345-6480.

Privacy Shield Policy

This Privacy Shield Policy (“Policy”) describes how SNOW COMPANIES, INC., and its
subsidiaries and affiliates in the United States (“US”) (“Snow”, “Company,” “We,” or “Us”)
collect, use, and disclose certain personally identifiable information that we receive in the US
from the European Union (“EU Personal Data”). This Policy applies to the following US
affiliated entities: Snow Health, LLC; Snow Link, LLC; Snow P2P, LLC. This Policy
supplements our Website Privacy Policy located at,
and unless specifically defined in this Policy, the terms in this Policy have the same meaning as
the Website Privacy Policy.

Snow recognizes that the EU has established strict protections regarding the handling of
EU Personal Data, including requirements to provide adequate protection for EU Personal Data
transferred outside of the EU. To provide adequate protection for certain EU Personal Data about
clients, consultants, business associates, and employees received in the US, we have elected to
self-certify to the EU-US Privacy Shield Framework administered by the US Department of
Commerce (“Privacy Shield”). Snow adheres to the Privacy Shield Principles of Notice, Choice,
Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access,
and Recourse, Enforcement, and Liability.

For purposes of enforcing compliance with the Privacy Shield, Snow is subject to the
investigatory and enforcement authority of the US Federal Trade Commission. For more
information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield
website located at: To review Snow’s representation on the
Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list
located at:

Personal Data Collection and Use

We receive EU Personal Data from consultants who, pursuant to the terms of written
contractual agreements, provide services to us in the EU (“Consultants”). We also receive EU
Personal Data from individuals within the EU who have been selected, or considered for
selection, for participation in a disease awareness initiative on behalf of a client (“Participants”).

Consultants: Consultants who provide services to us within the EU do so under the terms
of a written contractor agreement. In connection with this contractual relationship, we collect the
following personal data: name; address; phone number; email address; tax identification number;
and banking information (used for paying invoices via wire transfer). This information is stored
in hard copy in a locked file cabinet in the HR department in Williamsburg, Virginia.
Information required to process payments to our Consultants and complete wire transfers is also
stored electronically by our payment processing department. We use this information to
communicate with our Consultants, to process payments to them, and to comply with
governmental reporting requirements.

Participants: The personal data that we collect from a Participant is provided by the
Participant during a personal consultation with a member of our staff. These consultations are
conducted, with very limited exceptions, telephonically or via other digital voice communication
technology, such as Skype. We use the information collected to determine a Participant’s
eligibility for various disease awareness initiatives and to communicate with a Participant
regarding the same. The information collected during a consultation includes the following:
name; address; telephone number; email address; medical diagnosis and related health
information; and brand names of pharmaceutical products used for treatment of the diagnosis.
We consider your personal health information that we collect sensitive EU Personal Data under
the Privacy Shield and treat it accordingly. Therefore, we will require your opt-in consent prior
to disclosing any sensitive EU Personal Data to third parties or before using your sensitive EU
Personal Data for any purpose other than that for which it was collected.

Snow will only use or process EU Personal Data, including sensitive EU Personal Data,
in ways that are compatible with the purpose that Snow collected it for, or for purposes that a
Consultant or Participant later authorizes. Before we use your EU Personal Data for a purpose
that is materially different than the purpose we collected it for or that you later authorized, we
will provide you with the opportunity to opt out. Snow maintains reasonable procedures to help
ensure that EU Personal Data is reliable for its intended use, accurate, complete, and current.

Data Transfers to Third Parties

Third-Party Agents or Service Providers. We may transfer EU Personal Data to our
third-party agents or service providers who perform functions on our behalf, including data
storage and management services, payment processing, and making travel arrangements. Where
required by the Privacy Shield, we enter into written agreements with those third-party agents
and service providers requiring them to provide the same level of protection the Privacy Shield
requires and limiting their use of the data to the specified services provided on our behalf. We
take reasonable and appropriate steps to ensure that third-party agents and service providers
process EU Personal Data in accordance with our Privacy Shield obligations and to stop and
remediate any unauthorized processing. Under certain circumstances, we may remain liable for
the acts of our third-party agents or service providers who perform services on our behalf for
their handling of EU Personal Data that we transfer to them.

Disclosures for National Security or Law Enforcement. Under certain circumstances,
we may be required to disclose your EU Personal Data in response to valid requests by public
authorities, including to meet national security or law enforcement requirements.


Snow maintains reasonable and appropriate security measures to protect EU Personal
Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance
with the Privacy Shield.

Access Rights

You may have the right to access the EU Personal Data that we hold about you and to
request that we correct, amend, or delete it if it is inaccurate or processed in violation of the
Privacy Shield. These access rights may not apply in some cases, including where providing
access is unreasonably burdensome or expensive under the circumstances or where it would
violate the rights of someone other than the individual requesting access. If you would like to
request access to, correction, amendment, or deletion of your EU Personal Data, you can submit
a written request to the contact information provided below. We may request specific
information from you to confirm your identity.

Questions or Complaints

You can direct any questions or complaints about the use or disclosure of your EU
Personal Data to us by calling our Privacy Officer at 1-757-345-6480, or by emailing us at We will investigate and attempt to resolve any complaints or
disputes regarding the use or disclosure of your EU Personal Data within 45 days of receiving
your complaint. For any unresolved complaints, we have agreed to cooperate with JAMS as our
ADR provider. If you are unsatisfied with the resolution of your complaint, you may contact
JAMS at or 212-607-2771 for further information and assistance.

Binding Arbitration You may have the option to select binding arbitration for the
resolution of your complaint under certain circumstances, provided you have taken the following
steps: (1) raised your compliant directly with Snow and provided us the opportunity to resolve
the issue; (2) made use of the independent dispute resolution mechanism identified above; and
(3) raised the issue through the relevant data protection authority and allowed the US Department
of Commerce an opportunity to resolve the complaint at no cost to you. For more information on
binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I
(Binding Arbitration).

Contact Us

If you have any questions about this Policy or would like to request access to your EU
Personal Data, please contact us as follows: or call 1-757-345-

Changes To This Policy

We reserve the right to amend this Policy from time to time consistent with the Privacy
Shield’s requirements.

Effective Date: July 1, 2016

Last modified: November 15, 2016

Snow Companies