Hygieia and iSage Rx Launch Technology Collaboration Supporting Hygieia’s Growing Network of Specialty-Care Clinics

Hygieia Inc. and its affiliates including Hygieia Research, LLC (referred to collectively as Hygieia), have established a comprehensive privacy program designed to help us respect and protect data privacy rights. Hygieia complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as established by the U.S. Department of Commerce and the European Commission concerning the collection, transfer, use, and retention of personal data from the European Union member countries and Switzerland. Hygieia certifies that it follows the Safe Harbor Privacy Principles published by the U.S. Department of Commerce with respect to all such data. If there is any conflict between this policy and the principles, the principles shall govern. For additional information regarding the Safe Harbor Principles, and to view Hygieia’s certification, please visit the U.S. Department of Commerce’s website at http://export.gov/safeharbor/

Scope

This Safe Harbor Privacy Policy sets forth how Hygieia handles information transferred from countries in the European Economic Area (EEA) and Switzerland to the United States. This may include both Personal Information and Sensitive Personal Information collected from employees, clients, customers, service providers, and/or healthcare professionals and transferred by on-line, off-line, written or verbal methods.

Definitions

Agent

A third party that processes data solely on behalf of and under the instructions of Hygieia.

Personal Information

Information that links to or can reasonably be used to link to a specific, living individual.

Sensitive Personal Information

Personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious beliefs, trade union membership or that concerns an individual’s health.

Privacy Principles

Notice

Hygieia will provide affected individuals information describing the purposes for which we collect and use personal data about them, how to contact us, the types of non-agent third parties with whom we may share information, and any means for limiting the use and sharing of such information. Notice will be provided, clearly and conspicuously, when individuals are first asked to provide information to Hygieia, or as soon as practicable thereafter, and in any event where information is used or disclosed for a purpose other than the original.

Choice

Hygieia will offer affected individuals the ability to choose (opt-out) whether their Personal Information is shared with a non-agent third party or used for a purpose other than the original intended or subsequently authorized purpose.
For Sensitive Personal Information, affected individuals will have the opportunity to explicitly affirm (opt-in) consent for Hygieia to disclose information to a third party or use it for a purpose other than the original intended or subsequently authorized purpose.

Onward Transfers

Hygieia will only transfer Personal Information to a third party consistent with the Notice and Choice principles stated above. Hygieia ensures that any third party to which Personal Information may be disclosed subscribe to the Safe Harbor Privacy Principles or are required to provide the same level of privacy protection. The third party must agree in writing to provide an adequate level of privacy protection.

Data Security

Hygieia will take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, destruction, and alteration. Appropriate physical, electronic, and managerial procedures are in place to safeguard and secure the Information.

Data Integrity

Personal Information will only be processed in a way that is relevant and compatible to the purpose for which it was collected or authorized. Hygieia will take appropriate steps to ensure all Information is accurate, complete, current, and reliable for its intended uses.

Access

Individuals will be provided with their Personal Information upon request. They may request the correction or amendment of data they demonstrate to be inaccurate.

Enforcement

Hygieia uses a self-assessment approach to assure compliance with this privacy policy. The policy is periodically reviewed for accuracy, implementation, access, and conformity to the Principles.
Adherence to these Principles by Hygieia may be limited to the extent required to meet legal, governmental, national security or public interest.
Individuals may request access to their information, ask questions related to our privacy practices, or issue a complaint by contacting Hygieia using the following information:

Leann Christman, Privacy Officer
Hygieia, Inc.
6276 Jackson Rd Suite G
Ann Arbor, MI 48103
info@hygieia.com

If an inquiry is not satisfactorily addressed, the EU Data Protection Authorities (who will provide Dispute Resolution) will be contacted to serve as a liaison to resolve concerns.

This Policy may be amended from time to time, consistent with the requirements of Safe Harbor. In this event, the last updated date at the bottom of this Policy will be revised.

This Policy was last updated on 12/1/2015