Privacy Shield Policy
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 firstname.lastname@example.org. 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 https://www.jamsadr.com/eu-us-privacy-shield or 212-607-2771 for further information and assistance.
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: email@example.com 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: June 21, 2019