Privacy Shield Policy
This Privacy Shield Policy (“Policy”) describes how Snow Companies, LLC, and its subsidiaries and affiliates in the United States (“US”) (“Company,” “we,” or “us”) collect, use, and disclose certain personally identifiable information that we receive in the US from the European Economic Area (“EEA”), the United Kingdom (“UK”), and Switzerland (“Personal Data”). This Policy applies to the following US affiliated entities: Snow Health, LLC; Snow Link, LLC; Snow P2P, LLC; SnoWest, LLC; Patient Ambassador Company, LLC; and MyPatientStory.com, LLC, all of which are referred to collectively as “Snow”. This Policy supplements our Website Privacy Notice located at www.snow-companies.com/privacy-notice/, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website Privacy Notice.
Snow recognizes that the EEA, the UK, and Switzerland have established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EEA, the UK, and Switzerland. To provide adequate protection for certain Personal Data about consumers, corporate customers, clients, suppliers, and business partners received in the US from the EEA, the UK, and Switzerland, Snow has elected to self-certify to the EU-US Privacy Shield Framework and the Swiss-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. Snow commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.
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: https://www.privacyshield.gov/list.
Personal Data Collection and Use
Our Website Privacy Notice located at www.snow-companies.com/privacy-notice/ describes the categories of Personal Data that we may receive in the US as well as the purposes for which we use that Personal Data. We may receive the following categories of Personal Data in the US: identifiers and personal information such as name, physical address, mailing address, email address, phone number, age, gender, and citizenship. We also may collect the following categories of sensitive Personal Data: race, ethnicity, and health information. When we collect sensitive Personal Data, we will obtain your opt-in consent where the Privacy Shield requires. We use Personal Data, including sensitive Personal Data, only to fulfill the purpose for which it was collected, such as considering eligibility to participate in patient support activities, managing and facilitating contractual arrangements with Snow’s clients, or engaging with our business partners and consultants. Snow will only process Personal Data in ways that are compatible with the purpose for which it was collected, or for purposes the individual later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose it was collected for or that you later authorized, we will provide you with the opportunity to opt out. Snow maintains reasonable procedures to help ensure that 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 Personal Data to our third-party service providers or agents who perform functions on our behalf as described in our Website Privacy Notice, such as 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 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 Personal Data that we transfer to them.
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your 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 Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
You have the right to access the 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 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. In some circumstances we may charge a reasonable fee for access to your information.
Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your Personal Data to us at [email protected]. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your 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 not satisfied 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 Personal Data, please contact us as follows: by email: [email protected]; by phone: 1-757-345-6480; by mail: Snow Companies, LCC, Attn: Privacy Officer, 133 Waller Mill Rd., Williamsburg, VA 23185 USA.
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 18, 2022