EU-Swiss Privacy Shield

EU-Swiss Privacy Shield Framework

Alanda, LLC (“Alanda”) assists pharmaceutical and medical device manufacturers companies in addressing their regulatory compliance needs by providing automated solutions and supportive consulting services. In providing these services, Alanda may make use of individuals’ personal information (name, address and email address) provided to Alanda by its clients. Protecting this personal data is important to Alanda. Alanda respects privacy and operates within the EU-US and Swiss-US Privacy Shield Framework published by the US Department of Commerce and described at https://www.privacyshield.gov/.

Alanda generally does not collect personal information directly from individuals, nor is Alanda’ website designed to obtain or collect personal information from individuals. With respect to such personal information that Alanda does collect and receive from individuals residing in the European Union (“EU”) or Switzerland, Alanda complies with the EU-U.S. and Swiss-US Privacy Shield Framework as established by the US Department of Commerce regarding the collection, use, and retention of personal information.

In addition, clients of Alanda may use software designed and supported by Alanda to collect personal information, and may make such information available to Alanda in order for Alanda to carry out the services purchased by them. With respect to personal information from individuals residing in the EU or Switzerland that is collected by clients of Alanda using Alanda systems, Alanda systems provide disclosures and resources to comply with the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework regarding the collection, use, and retention of personal information.

ALANDA Software complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively.  ALANDA Software has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

ALANDA Software is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

In compliance with the US-EU and Swiss-US Privacy Shield Principles, ALANDA Software commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact ALANDA Software at:

Email: privacyshield@alandasoftware.com
Phone: 1.201.386.8007

ALANDA Software has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Notice

Alanda shall inform individuals about the purpose for which it collects and uses their Personal Information, the types of third parties to whom Alanda may disclose the information, how to contact Alanda with inquiries and complaints, and the choices and means Alanda offers individuals for limiting the use and disclosure of their Personal Information. Alanda shall provide such notice in two instances: (1) prior to using Personal Information for a purpose other than that for which it was originally collected by Alanda’ client, or (2) prior to disclosing Personal Information to a third party who is not the original source of the information.

Choice

Alanda shall provide individuals an opportunity to choose (or “opt-out”) whether their personal information is (a) to be disclosed to a third party, or (b) used for a purpose other than that for which it was originally collected by Alanda’ client or subsequently authorized by the individual. Such choice can be exercised by utilizing the contact information outlined below. Alanda shall not disclose an individual’s sensitive Personal Information, or use it for a purpose other than that for which it was originally collected or subsequently authorized by the individual, unless the individual expressly consents (or “opts-in”) to that use or disclosure.

Accountability for Onward Transfers

Alanda receives personal information from Clinical Research, Meeting Management and Consulting firms (Third Party/Parties) who are contracted by Alanda clients to provide transaction data which is reportable for EFPIA and government reporting purposes. Alanda may provide corrections to the name, address and email information submitted to Alanda Clients from third parties.

When disclosing personal information to a third party Alanda shall ensure that the third party is Privacy Shield certified or that the Alanda client with whom they have a contractual relationship has agreed in writing either via model clauses or through Privacy Shield certification to adhere to the principles of the EU-US and Swiss-US Privacy Shield. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield, ALANDA Software is potentially liable. For more information, see https://www.privacyshield.gov/EU-US-Framework.

Security

Alanda shall take reasonable precautions to secure personal information and protect it from loss, misuse, and unauthorized access, alteration and destruction, by using physical, electronic and managerial safeguards. Alanda cannot guarantee the security of Information on or transmitted via the Internet.

Data Integrity and Purpose Limitation

Alanda shall only use personal information that is relevant to the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for those purposes, Alanda shall take reasonable steps to make sure that personal information is accurate, complete, current and reliable for its intended use.

Access

Alanda acknowledges the right of individuals to access their personal data.  Individuals may have reasonable access to their personal data to correct, amend or delete information that is inaccurate with the approval of the client company-owner of the data. Alanda may require an individual to provide acceptable proof of identity prior to granting reasonable Access Requests individuals shall be provided access by using the contact ALANDA SOFTWARE information outlined below. Alanda shall also reserve the right to restrict an individual’s access if it determines (1) the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or (2) where the rights of persons other than the individual would be violated.

Recourse, Enforcement and Liability

Alanda shall periodically verify, through self-assessment, that the policy continues to conform to the EU-US and Swiss-US Privacy Shield Principles, that its employees are trained in implementing the policy, that it has in place procedures for disciplining employees for non-compliance, and that Alanda is in general compliance with its policy and the EU-US and Swiss-US Privacy Shield Framework. Individuals with inquiries or complaints regarding this privacy policy or regarding any use or disclosure of their personal information should first contact Alanda at:

Email: privacyshield@alandasoftware.com
Phone: 1.201.386.8007

Individuals should provide their name, contact information, and a brief message describing their concerns. Charges incurred by the individual in calling the number provided above can be reimbursed by Alanda upon request of the individual.