Updated: January 4, 2018
Snow receives personal and health-related information from patient ambassadors and individuals who nominate themselves to be patient ambassadors. Snow also receives personal and health-related information from individuals who call in to informational or educational call centers operated by Snow on behalf of a client. All personal information collected by Snow is provided voluntarily by the individual. Individuals may provide personal information through the submission of surveys and/or questionnaires distributed by Snow through a variety of media and communication channels. Individuals also may provide personal information when they contact a call center and are interviewed by Snow personnel, or individuals acting on behalf of Snow. The types of personal information collected by Snow varies, depending upon the reason an individual contacts Snow, but may include name, contact information (both physical and electronic), date of birth, social security number, family information, photographic image, and personal health information. All personal information collected by Snow is collectively referred to as “Collected Data”.
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 individuals who voluntarily submit Collected Data to Snow to be considered for participation in a patient ambassador or other educational engagement, the Collected Data is used to determine potential opportunities for those who have requested consideration for such opportunities. In all other instances, Collected Data is used to enable Snow to respond to the request or inquiry of a caller.
Snow does not transfer, sell, rent, or lease any Collected Data to third-parties unless required by law or your prior permission is obtained. If Collected Data is obtained on behalf of a client, we will advise you at the time we collect the information from you and we will obtain your consent before we transfer any Collected Data to the client. For information collected online, Snow neither utilizes cookies nor employs any behavioral tracking devices.
We may store information that is not personally-identifiable, such as your area code, your zip code, or a medical diagnosis, separate and apart from any personally-identifiable information or other Collected Data for our own internal purposes, such as tracking and data analysis.
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. In addition, an individual who is not otherwise engaged in an ongoing business relationship with Snow, such as serving as a patient ambassador, may request that Snow delete his/her Collected Data by sending a written request to the address shown below. Within seven (7) days of receipt of a written request, Snow will delete any Collected Data as requested. All requests to access, review, modify, or delete Collected Data should be directed to firstname.lastname@example.org, or Robin Branscome, Privacy Officer, Snow Companies, LLC, 133 Waller Mill Rd., Williamsburg, VA 23185, or, via phone, at 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.
Privacy Shield 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: https://www.privacyshield.gov. To review Snow’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: www.privacyshield.org.
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.
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 email@example.com. 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 SafeHarbor@jamsdr.com 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).
If you have any questions about this Policy or would like to request access to your EU Personal Data, please contact us as follows: firstname.lastname@example.org or call 1-757-345-6480.
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: January 4, 2018