Privacy policy: ARIRDMSCRO Privacy Policy (The “Policy”):

ARIRDMSCRO (also referred to as “Company”, “we” or “our”) respects the relationships we have with our customers and respects the privacy of all individuals who’s Personal Information may be processed by ARIRDMSCRO in the performance of our services and our business operations.

This Privacy Policy applies around the geographical operations of ARIRDMSCRO. This Policy explains how ARIRDMSCRO collects, holds, uses and discloses Personal Information, including Personal Information of our personnel, consumers, healthcare professionals, patients, medical research subjects, clinical investigators, customers, suppliers, vendors, business partners and investors. ARIRDMSCRO intends that this corporate privacy policy and our implementing standard practices and procedures will support timely compliance with all currently available privacy laws and regulations in India.

SCOPE:

This Policy applies to all Personal Information of Individuals, either in electronic or paper format, received by ARIRDMSCRO, including Personal Information of Company Personnel, consumers, healthcare professionals, patients, medical research subjects, clinical investigators, customers, suppliers, vendors, business partners and investors.

DEFINITIONS:

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

• “Agent” means any third party that uses Personal Information provided to it by ARIRDMSCRO to perform tasks on behalf of and/or under the instructions of ARIRDMSCRO or to which ARIRDMSCRO discloses Personal Information for use on its behalf.
• “Individual” means any natural person.
• “Personal Information” means any information or set of information about an identified or identifiable individual, including, but not limited to: (a) first name or initial and last name; (b) home or other physical address; (c) telephone number; (d) email address or online identifier associated with the individual; (e) AADHAR number with details or other similar identifier; or (f) any other information relating to an individual that is combined with any of the above. The term “Personal Information” does not include non-identified information or information that is reported in the aggregate (provided that such aggregated information is not identifiable to a natural person).
• “Personnel” includes, but is not limited to, any employee (permanent or temporary), director, officer, contractor, worker, temporary worker, job applicant, retiree of ARIRDMSCRO and any and all of their respective dependents.
• “ARIRDMSCRO” means any entity that directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under common control with ARIRDMSCRO. For purposes of this definition, “control” means the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of such entity, whether through the ownership of voting securities, by contract or otherwise.

“Sensitive Personal Information” means Personal Information that reveals or is processed to uniquely identify a person:

• All government-issued identification numbers (including AADHAR details, as applicable for international clinical trials and clients their (US Social Security numbers, EU Social Security numbers, Canadian Social Insurance numbers, driver’s license numbers, and passport numbers).
• All financial account numbers (bank account numbers, credit card numbers, and other information if that information would permit access to a financial account).
• Individual medical records, biomedical specimens, and biometric information, including any information on any worker or consumer’s health, disability, disease or product interests;
• Reports of individual background checks.
• Data elements revealing race, ethnicity, national origin, political opinion, religious or philosophical beliefs, trade union membership, genetic data, biometric data where processed to uniquely identify a person, any information that concerns medical or health conditions or sex life, or information relating to the commission of a criminal offense sex life or sexual orientation, and information relating to the commission of a criminal offense.

NOTICE

Where ARIRDMSCRO collects Personal Information directly from Individuals, it will explain the purposes for which it collects and uses Personal Information about the Individuals, the types of third parties to which ARIRDMSCRO discloses that information, and the choices and means, if any, ARIRDMSCRO offers Individuals options for limiting the use and disclosure of Personal Information about them. This explanation will be provided as soon as practicable and, in any event, before ARIRDMSCRO discloses the Personal Information or uses such information for a purpose materially different than that for which it was originally collected or processed. ARIRDMSCRO also will provide any additional information required by law for a specific context, product or service. In general, with exceptions and other lawful bases that may be relevant for any specific product or service notice, ARIRDMSCRO processes personal data for its legitimate interests consistent with applicable law. Where an ARIRDMSCRO entity receives Personal Information from another ARIRDMSCRO entity or other entities, including when acting as a CRO processing Personal Information under the direction of a customer, 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.

Types of Personal Information collected, Purposes of Collection and Uses of Personal Information:

• Research Studies-Related Information. For Individuals participating in research studies being managed by ARIRDMSCRO as a CRO, including patients, their spouses/partners, care givers, and relatives, clinical investigators or other study personnel, and other consultants, contractors, managers, and agents (who are natural persons) of the study sponsor and its corporate affiliates, business partners and third-party service providers, Personal Information may be used in order to carry out the applicable studies and other study-related services and/or pharmacovigilance. This may include the transfer of such Personal Information to the applicable study sponsor, its corporate affiliates, business partners and third-party service providers performing services related to the study (e.g., study data management, clinical research monitoring services, safety monitoring, etc.).

• Human Resources-Related Information. For Individuals who are Personnel, we will process Personal Information to carry out and support our human resources functions and activities, including but not limited to, employment opportunities, Personnel recruitment and onboarding, administration of Personnel participation in benefits, compensation and human resources plans and programs, management of Personnel performance, and implementation, investigation and reporting on compliance and discipline procedures and matters. ARIRDMSCRO may provide Personal Information to Agents to support ARIRDMSCRO in performance of these human resources-related activities.

• Customers and Program Participant Information. For Individuals sharing Personal Information with ARIRDMSCRO in order to inquire about or otherwise make use of our services or purchase, receive or seek information, including about any health care products and services, opportunities to participate in clinical research, health care education and patient support programs which may be available through ARIRDMSCRO, we will use such Personal Information in order to provide the requested information, products, and/or services. Such uses may include processing requested transactions, improving the quality of our services, sending communications about the products and services available through ARIRDMSCRO, and enabling our business partners and Agents to perform certain activities on our behalf.

ARIRDMSCRO may also use the Personal Information collected above to comply with our legal and regulatory obligations, policies and procedures, and for internal administrative purposes.

CHOICE

ARIRDMSCRO may offer Individuals the opportunity to choose whether their Personal Information is (a) to be disclosed to a third party, or (b) to be used for a purpose materially different from the purpose for which it was originally collected or subsequently authorized by the Individual.

ARIRDMSCRO will not process Sensitive Personal Information about Individuals for purposes other than those for which the information was originally obtained or subsequently authorized by the Individual unless the Individual explicitly consents to the processing (“opt-in”), or as required or permitted, or where not prohibited by law or regulation.

In some cases, even if an Individual opts-out of disclosures of their Personal Information, ARIRDMSCRO may still disclose such Personal Information (i) if required to do so by law, (ii) if disclosure is required to be made to law enforcement authorities, or (iii) if we believe disclosure is necessary or appropriate to prevent physical harm to an individual or financial loss or in connection with an investigation of suspected or actual illegal activity. ARIRDMSCRO also may transfer Personal Information when a material event concerning its business operation(s), assets or shares, such as purchase, disposal, merger, joint venture or acquisition, is proposed or occurs. In such an event, ARIRDMSCRO will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Policy. ARIRDMSCRO will provide Individuals with reasonable mechanisms to exercise their choices to the extent required by applicable law.

ACCOUNTABILITY FOR ONWARD TRANSFER

In the performance of our services and business operations, Personal Information we collect or receive may be stored or transferred internationally throughout our worldwide work regions and to our service providers or agents, including for hosting our databases or provision of data processing services, in accordance with applicable data privacy laws. Transfers to third parties are covered by the provisions in this Policy regarding notice and choice.

ARIRDMSCRO may also share an Individual’s Personal Information with Agents in connection with services that these individuals or entities perform for, or with, ARIRDMSCRO. ARIRDMSCRO may, for example, provide an Individual’s Personal Information to Agents for hosting our databases, for data processing services, or to send to that Individual the information that he or she requested.

ARIRDMSCRO may transfer Personal Information for specified, limited purposes, to an Agent and will endeavor to obtain assurances that such Agent provides at least the same level of privacy protection as is required by the Privacy protect principles (where applicable) and this Policy and will notify ARIRDMSCRO if it makes a determination it can no longer meet this obligation.

Where ARIRDMSCRO knows that any third party to whom it has provided Personal Information is using or disclosing Personal Information in a manner contrary to this Policy, ARIRDMSCRO will take reasonable steps to prevent or stop the use or disclosure. With respect to such onward transfers to Agents, and to the extent ARIRDMSCRO is responsible for the event, ARIRDMSCRO shall remain liable should its Agents process Personal Information in a manner inconsistent with the Privacy Shield Principles (where applicable) and this Policy.

SECURITY

ARIRDMSCRO will employ reasonable and appropriate technical, administrative and physical safeguards designed to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Information ARIRDMSCRO is processing. We have a privacy incident response program designed to promptly respond to and escalate all privacy-related questions, complaints, concerns, including any potential privacy or security incident.

DATA INTEGRITY AND PURPOSE LIMITATION

ARIRDMSCRO endeavors to use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the Individual. ARIRDMSCRO will take reasonable steps designed to ensure that only Personal Information that is relevant to its intended use, accurate, complete, current, and otherwise reliable in relation to the purposes for which the information was obtained is used by ARIRDMSCRO for as long as ARIRDMSCRO retains possession of such information. ARIRDMSCRO’s Personnel have a responsibility to assist ARIRDMSCRO in maintaining accurate, complete and current Personal Information. When acting as a CRO, ARIRDMSCRO endeavors only to process Personal Information that is relevant to the services it provides, and for purposes compatible with those for which the Personal Information was collected; wherever possible, such Personal Information is non-identified. Where ARIRDMSCRO processes Personal Information as a CRO under the direction of its customers, ARIRDMSCRO works with such customers so that the customers can provide a way for Individuals to correct or update their Personal Information to the extent required by law.

ACCESS/CORRECTION

Under laws in certain countries in which we operate, individuals have a right to access Personal Information about themselves, and to amend, correct or delete Personal Information that is inaccurate, incomplete or outdated. ARIRDMSCRO will, on request, provide an Individual with confirmation regarding whether ARIRDMSCRO is processing Personal Information about them, consistent with applicable law. In addition, upon request of an Individual, ARIRDMSCRO may take reasonable steps to correct, amend, or delete their Personal Information that is found to be inaccurate, incomplete or processed in a manner non-compliant with this Policy or applicable law, except where the burden or expense of providing access would be disproportionate to the risks to that Individual’s privacy, where the rights of persons other than the Individual would be violated or where doing so is otherwise consistent with applicable law. Unless prohibited by applicable law, ARIRDMSCRO reserves the right to charge a reasonable fee to cover costs for providing copies of Personal Information requested by Individuals. ARIRDMSCRO, when acting as a CRO, has no direct relationship with medical research subjects participating in a clinical trial and any such Individuals who seek access, or who seek to correct, amend, or delete their inaccurate Personal Information should direct his or her query to the relevant study sponsor or investigator which has transferred such Personal Information to ARIRDMSCRO for processing.

Although ARIRDMSCRO makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which ARIRDMSCRO is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If ARIRDMSCRO determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, ARIRDMSCRO will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Where otherwise permitted by applicable law, you may send an e-mail to hr@arirdmscro.com or use any of the methods set out in this Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by ARIRDMSCRO. Such requests will be processed in line with local laws.

RECOURSE, ENFORCEMENT AND LIABILITY

ARIRDMSCRO encourages Individuals covered by this Policy to raise questions about the processing of Personal Information about them by contacting ARIRDMSCRO through the contact information provided below. Any Personnel that ARIRDMSCRO determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment, where applicable.

Any questions or concerns regarding the use or disclosure of Personal Information should also be directed to ARIRDMSCRO through the contact information given below. ARIRDMSCRO will undertake reasonable efforts to investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy.

RESERVATION OF RIGHTS: ARIRDMSCRO reserves the right to share an Individual’s Personal Information and contracts with Agents as required or authorized by law or regulation or in response to duly authorized information requests of government authorities.

CHANGES TO THE PRIVACY POLICY: This Policy may be reviewed and amended from time to time, without advance notice, to ensure that an appropriate level of protection for Personal Information is maintained. All amendments will be posted on this website. Please check back periodically for updates to this Policy.

ARIRDMSCRO PRIVACY POLICY EFFECTIVE DATE: May 31, 2020

Privacy

See ARIRDMSCRO’s Online website for privacy statement.

Information Provided to ARIRDMSCRO

ARIRDMSCRO does not want you to, and you should not, send any confidential or proprietary information to ARIRDMSCRO via the Web site. Any submission by you to ARIRDMSCRO, including but not limited to questions, comments, suggestions or the like shall be deemed to be non-confidential and shall become the property of ARIRDMSCRO. Furthermore, by your submission you grant ARIRDMSCRO an unrestricted, irrevocable license to use, reproduce, display, perform, modify, transmit, and distribute such information. ARIRDMSCRO shall be free to use any ideas, concepts, know-how or techniques contained in such information for any purpose whatsoever, including but not limited to developing, manufacturing, and marketing products incorporating such information

Electronic Communications

When you visit www.ARIRDMSCRO.com or send e-mail to us, you are communicating with us electronically. Accordingly, you explicitly consent to receive communications from us electronically. We will communicate with you by e-mail or by posting notices on this Web site. You agree that all agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.

For all Emails sent from ARIRDMSCRO

All Emails ID of arirdmscro.com needs to add the following text as disclaimer below their incoming and outgoing signatures, as mandated by management:

CONFIDENTIAL
This message and any attachments (the “Message”) are confidential and intended solely for the addressee(s). If you are not the intended recipient, any use, copying or dissemination is strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return and delete this original Message and any copies from your system. E-mails are susceptible to alteration. arirdmscro and its subsidiaries and other affiliates shall not be liable if the Message is altered, changed or falsified.

This is an environment friendly email. Please do not print it unless it is really necessary.

Disclaimer of Warranties

ARIRDMSCRO makes no express or implied warranties, representations or endorsements whatsoever with respect to the web site or the content. ARIRDMSCRO expressly disclaims all warranties of any kind, express, implied, statutory or otherwise, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, title and non-infringement, with regard to the web site, the content, and any product or service furnished or to be furnished via the web site. ARIRDMSCRO does not warrant that the functions performed by the web site will be uninterrupted, timely, secure or error-free, or that defects in the web site will be corrected. ARIRDMSCRO does not warrant the accuracy or completeness of the content, or that any errors in the content will be corrected the web site and the content are provided on an “as is” and “as available” basis.

Limitation of Liability

In no event will ARIRDMSCRO be liable for any damages whatsoever, including, but not limited to any direct, incidental, consequential, special, exemplary or other indirect damages arising out of (i) the use of or inability to use the web site or the content, (ii) any transaction conducted through or facilitated by the web site; (iii) any claim attributable to errors, omissions, or other inaccuracies in the web site, the service and/or the content, (iv) unauthorized access to or alteration of your transmissions or data, or (v) any other matter relating to the web site, or the content, even if ARIRDMSCRO has been advised of the possibility of such damages. if you are dissatisfied with the web site, the content, or with the terms of use, your sole and exclusive remedy is to discontinue using the web site.

Because some states in India do not allow the exclusion or limitation of liability for consequential or incidental damages, some of the above limitations may not apply to you. In such states, ARIRDMSCRO ‘s liability is limited and warranties are excluded to the greatest extent permitted by law, but shall, in no event, exceed INR 10,000.

Copyright Act

ARIRDMSCRO is committed to complying with Indian copyright law and to responding to claims of copyright infringement. ARIRDMSCRO will promptly process and investigate notices of alleged infringement and will take appropriate actions under the Indian law.