This Policy applies to the processing of Customer Personal Data that LifeMap receives in the United States concerning Customers who reside in EU and Switzerland.
This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible).
- RESPONSIBILITIES AND MANAGEMENT
LifeMap has designated an internal team to oversee its information security program, including its compliance with the Privacy Shield program. The internal team shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to email@example.com.
LifeMap will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. LifeMap personnel will receive training, as applicable, to effectively implement this Policy.
- RENEWAL / VERIFICATION
LifeMap will renew its Privacy Shield certification annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.
Prior to the re-certification, LifeMap will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, LifeMap will undertake the following:
- Ensure that this Policy continues to comply with the Privacy Shield principles
- Confirm that Customers are made aware of the process for addressing complaints and any independent dispute resolution process (LifeMap may do so through its publicly posted website, Customer contract, or both)
- Review its processes and procedures for training Employees about LifeMap's participation in the Privacy Shield program and the appropriate handling of Customer Personal Data
- COLLECTION AND USE OF PERSONAL DATA
LifeMap provides various solutions to its Customers. LifeMap collects Personal Data from Customers when they purchase our products, register with our website, log-in to their account, complete surveys, request information from us, or otherwise communicate with us.
The Personal Data that we collect may vary based on the Customer's interaction with our website and request for our services. As a general matter, LifeMap collects the following types of Personal Data from its Customers: contact information, including, a contact person's name, work or personal email address, work mailing address, telephone number, title, and company name.
Customers may also upload data about their patients into LifeMap’s TGex which may include Personal Health Information (PHI), including name, sex, medical and family history, birth date and genetic data. This information is stored encrypted in our systems, and can only be accessed by (1) members of your account, or (2) by us to provide you with support services.
When Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website.
LifeMap uses Personal Data that it collects directly from its Customers and Customers' customers indirectly in its role as a service provider for the following business purposes, without limitation: (1) maintaining and supporting its products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including managing transactions, reporting, invoices, renewals, and other operations related to providing services to a Customer); (2) satisfying governmental reporting, tax, and other requirements (e.g., import/export); (3) storing and processing data, including Personal Data, in computer databases and servers located in the United States; (4) verifying identity (e.g., for online access to accounts); (5) as requested by the Customer; (6) for other business-related purposes permitted or required under applicable local law and regulation; and (7) as otherwise required by law.
- DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA
Except as otherwise provided herein, LifeMap discloses Personal Data only to Third Parties who reasonably need to know such data. Such recipients must agree to abide by confidentiality obligations. All Third Parties receiving personal information must have a written confidentiality agreement in place between Customer and Third Party and LifeMap and Third Party that meets or exceeds Privacy Shield standards.
LifeMap also uses third part processors for analytics on usage trends of our solutions, advertising on our platform, and for support purposes. These include Google Analytics, Google ads (DFP), SessionCam and others.
LifeMap may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by LifeMap and they must either: (1) comply with the Privacy Shield principles or another mechanism permitted by the applicable European and Swiss data protection law(s) for transfers and processing of Personal Data; or (2) agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy. LifeMap also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure.
LifeMap may be forced to disclose an individual's personal information when compelled by a request made by a recognized public authority or where required to meet national security and or law enforcement requirements.
In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US Privacy Shield, LifeMap is potentially liable. LifeMap's liability under this agreement will be governed by the contract in place between Customer and LifeMap.
- SENSITIVE DATA
LifeMap‘s only collects Sensitive Data from its Customers in TGex, as described in section IV above.
- DATA INTEGRITY AND SECURITY
LifeMap uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. LifeMap has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to LifeMap's electronic information systems requires user authentication via password or similar means, as well as two-factor authentication methods. LifeMap also employs access restrictions, limiting the scope of employees who have access to Customer Personal Data. Further, LifeMap uses secure encryption technology to protect certain categories of personal data.
Despite these precautions, no data security safeguards guarantee 100% security all of the time.
- ACCESSING PERSONAL DATA
LifeMap personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
- RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
Right to Access. As a user of the LifeMap tool, you have the right to access your data at any time. Data subjects have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which LifeMap collected the Personal Data. Data Subjects may review their own Personal Data stored in the databases and request to correct, erase, or block any data that is incorrect, as permitted by applicable law. Upon reasonable request and as required by the Privacy Shield principles, LifeMap allows Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Note that personal data is removed from our systems permanently upon closure of Customer accounts, and in those cases, personal information is no longer accessible or editable.
Customers may edit their Personal Data by logging into their account profile or by contacting LifeMap via LifeMap’s support system or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Customers should submit a written request to LifeMap via email or via the support system. Persons that have submitted their Personal Data to a LifeMap Customer should contact the Customer in the first instance to update their data.
Requests for Personal Data. LifeMap will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If LifeMap receives a request for access to his/her Personal Data from a Customer's customer, then, unless otherwise required under law or by contract with such Customer, LifeMap will refer such Data Subject to Customer.
Satisfying Requests for Access, Modifications, and Corrections. LifeMap will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.
Limiting Use of Personal Data. You may request limitations on the use of your personal data specified in this agreement by contacting us at firstname.lastname@example.org
- CHANGES TO THIS POLICY
This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.
- QUESTIONS OR COMPLAINTS
Customers may contact LifeMap with questions or complaints concerning this Policy at the following address: email@example.com.
In compliance with the Privacy Shield Principles, LifeMap Sciences commits to to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact LifeMap Sciences at the following email address: firstname.lastname@example.org.
LifeMap Sciences has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.
- ENFORCEMENT AND DISPUTE RESOLUTION
Customers with questions or concerns about the use of their Personal Data should contact us at email@example.com. In compliance with the Privacy Shield Principles, LifeMap commits to resolve complaints about our collection or use of your personal information. Individuals in the EU and/or Switzerland with inquiries or complaints regarding our Private Shield policy should first contact support@LifeMap.com. We will respond to all complaints within forty five (45) days.
As part of this agreement, LifeMap subjects itself to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Under certain conditions, more fully described on the Privacy Shield website (https://www.privacyshield.gov), you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
"Customer" means a prospective, current, or former partner (distributor or reseller), vendor, supplier, customer, or client of LifeMap, or anyone that has registered at the LifeMap websites or services. The term also shall include any individual agent, employee, representative, customer, or client of a LifeMap Customer where LifeMap has obtained his or her Personal Data from such Customer as part of its business relationship with the Customer.
"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.
"Employee" means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of LifeMap or any of its affiliates or subsidiaries
"Europe" or "European" refers to a country in the European Economic Area.
"Personal Data" as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual's name in combination with country of birth, , address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term "person" includes both a natural person and a legal entity, regardless of the form of the legal entity.
"Sensitive Data" means Personal Data that discloses a Data Subject's medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.
"Third Party" means any individual or entity that is neither LifeMap nor a LifeMap employee, agent, contractor, or representative.