US Micron, LLC Privacy Policy (US Micron is Part of The Micron Group)

Data Privacy Framework Privacy Policy

US Micron, LLC (“USM”) is committed to protecting your privacy. This privacy policy (the “Policy”) sets out the privacy principles which USM follows with respect to transfers of personal data from the European Union (EU), Switzerland, and the United Kingdom (and Gibraltar) (UK) to the United States including personal data relating to employees, customers, business partners as well as the personal information of healthcare professionals and clinical study participants where USM is providing services to its customers as a Clinical Research Organization.

Data Privacy Framework

USM complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. USM has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. USM has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Scope

This Policy applies to all personal information, whether in electronic or paper format, received by USM in the United States from the EU, the United Kingdom, and Switzerland and outlines our general policy for the implementation of the Principles.

Definitions

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

“Agent” means any third-party processing personal information on behalf of, and under the instruction of USM.

“European Union” or “EU” means for the purposes of this Policy all countries within the European Economic Area (EEA).

“Personal data” and “personal information” means data about an identified or identifiable individual that are within the scope of the Directive, received by USM in the United States from the European Union, and recorded in any form. It does not include personal information that has been anonymized or that is publicly available, that has not been combined with non-public personal information.

“Processing” of personal data means any operation or set of operations which is performed upon personal data, whether or not by automated means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction.

“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information that concerns health or sex life. In addition, USM will treat as sensitive, 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 in accordance with the principles set out in the EU-US DPF and the UK Extension to the EU-U.S. DPF and the Swiss-US DPF.

Notice

Where USM collects personal information directly from individuals in the EU, the UK, or Switzerland, it will inform them about the purposes for which it collects and uses personal information about them, the types of non-agent third parties to which USM discloses that information, and the choices and means, if any, that USM 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 USM, or as soon as practical thereafter, and in any event before USM uses the information for a purpose other than that for which it was originally collected.

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

During the conduct of its operations, USM may collect and process personal information relating to:

• Study participants, clinical research investigators and their staff as well as medical and healthcare professionals. The collection of personal information such as contact information, qualifications, debarment status and account information is to facilitate the proper conduct of research studies and to carry out other study related services. Information collected may be transferred to the Sponsor of a study, business partners, USM affiliates, and third-party service providers performing study-related duties and may furthermore be transferred to regulatory authorities;

• Customers, vendors and consultants. USM keeps contact information, account numbers and information relating to billing, together with other information which may be necessary for the daily operation of USM's services including conducting customer, product and service surveys, direct marketing of products and services, handling customer complaints and enquiries, making disclosure under the requirements of any law applicable, any other directly related matters;

• Human resources data such as curriculum vitae, contract information, residential address, date of birth, gender, government identification number, account information, qualifications and training records, debarment status, performance reviews, which is processed to support USM's human resources functions and activities including the administration of employee benefits, compensation, management of employee performance, business planning, disciplinary procedures including the investigation and reporting of complaints and for compliance with legal obligations, policies and procedures

• Prospective study participants, prospective investigators and users of USM applications and websites who make enquiries regarding USM services may be asked to provide personal information in order to provide the requested information, products or services. Personal information provided may be used for the processing of requested transactions, improving the quality of our services, sending communications about our products and services, enabling our business partners and service providers to perform certain activities on our behalf and complying with our legal obligations, policies and procedures.

  USM may use the personal information it collects to comply with our legal obligations, policies and procedures and for internal administrative purposes.

  Personal information collected and/or processed may be disclosed to a particular study sponsor, third party service provider, business partner and/or where required, regulators. USM may not need to furnish notice where processing is necessary to respond to a government inquiry, is required or authorized by applicable laws, court orders or government regulations, or is necessary to protect USM's legal interests and providing notice would interfere with the above requirements.

  Note on Clinical Trial Subject Data: Under the Data Privacy Framework, key-coded data is not considered protected Personal Data if the company does not receive the key. It is USM’s policy to only receive key-coded clinical subject data. In the event that USM comes in contact with un-redacted clinical trial Personal Data, USM will adhere to the Principles with respect to the Processing of such Personal Data.

Choice

USM offers individuals the opportunity to choose (opt out) whether their personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. Individuals will be provided with clear, conspicuous, and readily available mechanisms to exercise their choice.

For sensitive information, USM will obtain affirmative express consent (opt in) from individuals if such information is to be (i) disclosed to a third party or (ii) used for a purpose other than those for which it was originally collected or subsequently authorized by the individuals through the exercise of opt-in choice. In addition, USM will treat as sensitive any personal information received from a third party where the third party identifies and treats it as sensitive.

Accountability for onward transfer

Transfers of personal information to a third party acting as a controller are covered by the provisions of this Policy regarding Notice and Choice Principles. USM holds contracts with the third-party controllers that provide that such data may only be processed for limited and specified purposes consistent with the consent provided by the individual and that the recipient will provide the same level of protection as the Principles and will notify USM if it makes a determination that it can no longer meet this obligation. The contract shall provide that when such a determination is made the third-party controller ceases processing or takes other reasonable and appropriate steps to remediate.

When transferring personal information to a third party acting as an Agent, USM: (i) transfers such data only for limited and specified purposes; (ii) has ascertained that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles; (iii) takes reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with the USM's obligations under the Principles; (iv) requires the agent to notify USM if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (v) upon notice, including under (iv), USM will take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) will provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department of Commerce upon request.

USM is potentially liable in cases of onward transfer to third parties of data of EU, UK, or Swiss individuals received pursuant to the Data Privacy Framework.

Security

USM takes reasonable precautions to protect personal information from loss, misuse and unauthorized access, disclosure, alteration, and destruction.

Data integrity and purpose limitation

USM uses personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. USM takes reasonable steps to ensure that personal information is reliable for its intended use, accurate, complete, and current. USM will only collect and store Personal Information that is relevant to fulfill the purpose and will retain such information no longer than appropriate to fulfill the purpose.

Access and correction

Upon request, USM will grant individuals reasonable access to the personal information it holds about them. In addition, USM will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or has been processed in violation of the Principles.

Verification

USM will use a self-assessment verification approach and conduct compliance audits of its applicable privacy practices to verify adherence to this policy. USM's employees receive ongoing privacy awareness training on USM's privacy principles and practices.

Recourse, enforcement, and liability

Any complaints or concerns regarding the use or disclosure of personal information transferred from the EU, the United Kingdom, or Switzerland to the US should in the first instance be directed to the USM Data Protection Officer at the email address given below. USM will investigate and attempt to resolve complaints in accordance with the Data Privacy Framework Principles within 45 days of receiving a complaint. Complaints that cannot be resolved internally will be referred to the applicable EU Data Protection Authorities, the Swiss Federal Data Protection and Information Commissioner (FDPIC), and the UK Information Commissioner's Office (ICO) and the Gibraltar Regulatory Authority (GRA) to address complaints and provide appropriate recourse, which will be provided free of charge to the individual. USM is committed to following the determination and advice of these authorities. Under certain circumstances, an individual may choose to invoke binding arbitration to resolve any disputes that have not been resolved by other means.

USM complies with the Data Privacy Framework Principles and is subject to the investigatory and enforcement powers of the Federal Trade Commission.

Any employee that USM determines is in violation of this policy will be subject to disciplinary action.

Limitation on scope of principles

Adherence by USM to this policy may be limited to the extent required to meet legal, governmental, or national security obligations, including requirements to cooperate with law enforcement.

Changes to this policy

This policy may be amended from time to time, consistent with the requirements of applicable laws and regulations. The revisions will take effect on the date of publication of the amended policy, as stated.

Contact information

Questions, complaints, or comments related to this policy, data processing or data collection should be submitted to the USM Data Protection Officer: