1. Safe Harbor Principles
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles (the "Safe Harbor Privacy Principles") and frequently asked questions (collectively the "U.S.-EU Safe Harbor Framework") to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to Personal Information transferred from the EU to the United States. The EEA also has recognized the U.S.-EU Safe Harbor Principles as providing adequate data protection (OJL 45, 15.2.2001, p. 47). A similar agreement between the United States Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland (the "U.S.-Swiss Safe Harbor Framework") enables U.S. companies to satisfy the adequate protection requirements under the Swiss Federal Act on Data Protection for Personal Information transferred from Switzerland. Consistent with its commitment to protect personal privacy, Warner Chilcott adheres to the U.S.-EU and U.S.-Swiss Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the Safe Harbor programs, and to view Warner Chilcott's certification, please visit http://www.export.gov/safeharbor/.
This Policy applies to all Personal Information received by Warner Chilcott in the United States from the EEA and Switzerland in any format, including electronic, paper or oral.
For purposes of this Policy, the following definitions shall apply:
"Agent" means any third party that uses Personal Information provided by Warner Chilcott to perform tasks on behalf of and under the instructions of Warner Chilcott.
"Warner Chilcott" means Warner Chilcott (US), LLC, its predecessors, successors, subsidiaries, divisions and groups in the United States of America.
"Personal Information" means any information or set of information that identifies or could be used by or on behalf of Warner Chilcott to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
"Sensitive Personal Information" means Personal Information that reveals race, national origin, political opinions, religion or philosophical beliefs, or trade union membership, or that concerns criminal convictions, health, marital status, or sexual orientation, preference or activities. In addition, Warner Chilcott will treat as Sensitive Personal Information any information received from a third party where that third party treats and identifies the information as sensitive.
4. Privacy Principles
The privacy principles in this Policy are based on the Safe Harbor Principles.
Notice: Where Warner Chilcott collects Personal Information directly from individuals in the EEA 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 Warner Chilcott discloses that information, and the choices and means, if any, Warner Chilcott 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 Warner Chilcott, or as soon as practicable thereafter, and in any event before Warner Chilcott uses the information for a purpose other than that for which it was originally collected.
Where Warner Chilcott receives Personal Information from its subsidiaries, affiliates or other entities in the EEA or Switzerland, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Information relates.
Choice: Warner Chilcott will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For Sensitive Personal Information, Warner Chilcott will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
Warner Chilcott will provide individuals with reasonable mechanisms to exercise their choices.
Data Integrity: Warner Chilcott will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Warner Chilcott will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current.
Transfers To Agents: Warner Chilcott will obtain assurances from its Agents that they will safeguard Personal Information consistent with this Policy. Where Warner Chilcott has knowledge that an Agent is using or disclosing Personal Information in a manner contrary to this Policy, Warner Chilcott will take reasonable steps to prevent or stop such use or disclosure.
Access And Correction: Upon request, Warner Chilcott will grant individuals reasonable access to Personal Information that it holds about them. In addition, Warner Chilcott will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
Security: Warner Chilcott will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Enforcement: Warner Chilcott will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. If Warner Chilcott determines that an employee is in violation of this Policy, such individual will be subject to disciplinary action up to and including termination of employment.
Dispute Resolution: Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the Warner Chilcott Legal Department at the address given below. In addition, if you have a complaint concerning the use or disclosure of Personal Information or Sensitive Personal Information, please contact the Warner Chilcott Legal Department. The Warner Chilcott Legal Department will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of Personal Information and Sensitive Personal Information in accordance with the principles contained in this Policy.
For complaints that cannot be resolved by the Warner Chilcott Legal Department between Warner Chilcott and the complainant, Warner Chilcott has agreed to participate in the dispute resolution procedures of the panel established by the European Union data protection authorities to resolve disputes pursuant to the U.S.-EU Safe Harbor Principles. In addition, for disputes pursuant to the Swiss Safe Harbor Principles, Warner Chilcott has agreed to cooperate and comply with the Federal Data Protection and Information Commissioner of Switzerland.
5. Internet Privacy
6. Contact Information
Questions or comments regarding this Policy should be submitted to the Warner Chilcott Legal Department by mail or e-mail as follows:
Legal Department Warner Chilcott (US), LLC 100 Enterprise Drive Rockaway, New Jersey 07866 U.S.A. E-mail: email@example.com
This Policy may be amended from time to time, consistent with the requirements of the EU and Swiss Safe Harbor Principles. Appropriate notice will be given concerning such amendments.
8. Effective Date
This Policy is effective July 26, 2012.