Safe Harbor Privacy Policy

Introduction

Ancillare, LP (Ancillare) is strongly committed to protecting all personal information of its employees, partners and all who do business with us. The company will uphold the highest level of standards in all its business practices which will ultimately protect any personal information that it receives from any outside party. This Privacy Policy applies to all information Ancillare collects, including this website, emails and information you provide to Ancillare offline.

The purpose of the Safe Harbor Privacy Policy (the “Policy”) is to set forth the Privacy Principles that Ancillare follows with respect to personal information/data received from the European Economic Area (EEA) and Switzerland.

Ancillare complies with the U.S.-EU Safe Harbor Framework and the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal data from European Union member countries and Switzerland. Ancillare has certified that it adheres to the Safe Harbor Privacy Principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement. To learn more about the Safe Harbor program and principles, and to view Ancillare’s certification, please visit www.export.gov/safeharbor.

Scope

This Safe Harbor Privacy Policy applies to all personal information received by Ancillare, LP in the United States from the EU and from Switzerland in any format including electronic, paper or verbal.

Definitions

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

Agent: Refers to any third party that processes personal data solely on behalf of and under the instructions of Ancillare, LP.

Ancillare: Means Ancillare, LP

Individual: Refers to any natural person located in the European Union or Switzerland whose personal information is shared with Ancillare, LP in the United States.

Personal Information: Is any information or set of information that identifies or could be used by or on behalf of Ancillare, LP to identify an individual. Personal data do not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public information.

Sensitive Personal Information: Personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sexual orientation.

Privacy Principles

Notice: When Ancillare collects personal information directly from individuals in the European Economic Area (EEA) and Switzerland, it will inform the individual about the type of personal information collected, the purposes for which it collects and uses the personal information, and the types of non-agent third parties to which Ancillare discloses or may disclose information, and the choices and means, if any, that Ancillare 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 or as soon thereafter as is practical.

Choice: Ancillare will offer individuals the opportunity to choose (opt-out) whether their personal information is: (1) to be disclosed to a non-agent third party; or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Data Integrity: Ancillare shall use personal information only in ways that are compatible with the purposes for which it was collected or authorized by the employee, customer, supplier or agent.

Onward Transfers: Ancillare may share an individual’s personal information with agents, contractors or partners of Ancillare in connection with services that these individuals or entities perform for, or with, Ancillare. Ancillare will obtain assurances that these third parties will safeguard all personal information in line with this Policy.

Ancillare shall obtain assurances from its agents that they will safeguard personal information in accordance with this Policy. Where Ancillare has knowledge that an agent is using disclosing personal information in a manner contrary to this Policy, Ancillare will take reasonable steps to prevent or stop the use or disclosure.

Security: Ancillare will ensure reasonable safeguards are in place to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Access: Upon request, Ancillare will grant individuals reasonable access to personal information that Ancillare holds about them. In addition, upon request, Ancillare will take reasonable steps to provide individuals with a means to correct, amend or delete their inaccurate or incomplete information.

Enforcement: Ancillare uses a self-assessment approach to ensure compliance with this Privacy Policy and periodically verifies that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. Ancillare encourages individuals covered by the Policy to raise any concerns to AncillarePrivacy@ancillare.com, and Ancillare will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information in accordance with the Principles.

Limitation on Scope of Principles
Adherence by Ancillare, LP to these Safe Harbor Principles may be limited to the extent required to meet a legal, governmental, national security or public interest obligation.

Contact Us
For questions, comments or concerns regarding the Policy, please contact us:

Director of Quality Assurance
Ancillare, LP
700 Enterprise Road
Horsham, PA 19044
AncillarePrivacy@ancillare.com

Changes to this Privacy Policy Statement

Ancillare will review and update this Privacy Policy Statement periodically to ensure consistency with the Principles.

This Privacy Policy was last updated on June 24, 2016.