Themis north america, inc.

Privacy Policy

Themis North America, Inc. (“THEMIS,” “we,” “us” or “our”) is a leading provider of platform analytics to the global pharmaceutical industry provided through our website at http://www.themisanalytics.com and/or any successor or similar services that reference this policy (collectively, the “Site”).  THEMIS is concerned about protecting the privacy of individuals who access the Site and/or whose information we may process via the Site as directed by our clients (“you”).

This privacy policy (the “Privacy Policy”) applies to all Personal Information (in any format) that THEMIS may receive or obtain through the Site.  It outlines how we collect, use, share and protect such information and certain rights you have with respect to such information.

By using the Site, you agree to accept practices, principles, and other terms described in this Privacy Policy.  Our Terms of Use, which are incorporated by reference as if fully set forth herein, apply to this Privacy Policy.

We reserve the right, at any time, to modify, alter, update or remove portions of this Privacy Policy or our Terms of Use.  We will post any revised policy on our Site.  Please check this Privacy Policy and the Terms of Use from time to time and the date of any updates as your continued use of this Site signifies your acceptance of any changed items.

For the purposes of this Policy:

“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Information.

“Personal Information” means information about an identified or identifiable individual received by THEMIS.

“Privacy Shield” or “Privacy Shield Framework” means the Privacy Shield framework issues by the U.S. Department of Commerce as described more fully at https://www.privacyshield.gov/.

“Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield.

“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Information on behalf of a Controller.

Required Disclosure Event” means any instance where disclosure of Personal Information is required by law or that THEMIS reasonably believes that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

Sensitive Personal Information” means Personal Information that relates to race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health or any information relating to an individual’s sex life.

  1. Notice
    1. Personal Information Collected through the Site.

THEMIS collects Personal Information through the Site, either as a Controller (with respect to Personal Information provided by Site users) or as Processor (based on Personal Information that we process on behalf of clients, who the Controllers in such instances).  The Personal Information we collect or may collect includes:

first and last name,

user ID, address;

telephone number,

email address;

job position;

department;

company name; and

other Personal Information as provided to us by our clients

 

We do not collect Sensitive Personal Information.  However, if we were to do so, we would require opt-in consent for the sharing of any Sensitive Personal Information.

By using the Site, users also may make available to us and we collect through the use of cookies certain non-personally identifiable Site analytic data (such as the type of your Internet server and browser, the web pages accessed, and the length of access).  This information may include, for example, (i) your browser type, (ii) IP address, (iii) length and frequency of Site access, (iv) pages visited, and (v) your total data use related to the Site.  While the Site is designed to use cookies, it does not require such use. Most Internet browsers enable you to erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions. You may use the Site without restriction even if you have blocked cookies on your browser.

 

  1. How Personal Information Is Used by Us

We use Personal Information as necessary to provide our products and services, to improve the performance of our Site, to communicate with you with respect to the Site, including, e.g., support issues, or as otherwise authorized by individuals to whom the Personal Information relates.  Subject to the terms of this Privacy Policy, we also may provide Personal Information to our clients to enable them to assess the scope of Site utilization on behalf of their organizations.

 

THEMIS retains Personal Information in a form that identifies or renders identifiable the relevant individuals in accordance with applicable laws and only for as long as it serves a purpose that is compatible with the purposes for which the Personal Information was collected or subsequently authorized.

 

  1. Choice

Except in the case of disclosure to affiliates, third-party Processors performing on our behalf, or in the case of Required Disclosure Events, THEMIS offers individuals the opportunity to choose whether their Personal Information may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized. You may contact THEMIS as indicated below regarding the THEMIS’ use or disclosure of their Personal Information.  Unless THEMIS offers individuals an appropriate choice, it will use Personal Information only for purposes that are materially the same as those indicated in this Policy.

  1. Accountability for Onward Transfer; Sharing of Personal Information with Third Parties.

We may share Personal Information with third party Controllers as well as Processors that we may retain to perform certain services on our behalf.  We reserve the right to use or disclose your Personal Information as necessary in response to any Required Disclosure Events.

 

In the event that THEMIS is sold, has its assets acquired or transferred, whether voluntarily or involuntarily, or merges or becomes affiliated with any other division, individual or entity, any customer information owned or under the control of THEMIS, may be one of the transferred assets.  We reserve the right, as part of such transaction, to transfer or assign the Personal Information and other information we have collected from users of the Site.

 

We will require any third party to which Personal Information may be disclosed to contractually agree to the standards described in the this Privacy Policy and limit use to limited and specified purposes consistent with the purpose for which such data was provided.

 

THEMIS remains liable under the Privacy Shield Principles if the company’s third-party Processor onward transfer recipients process relevant Personal Information in a manner inconsistent with the Privacy Shield Principles, unless THEMIS proves that it is not responsible for the event giving rise to the damage

 

THEMIS will make commercially reasonable efforts to protect the Personal Information it collects from loss, misuse and unauthorized access, disclosure, alteration and destruction.  THEMIS has put in place appropriate physical, electronic and managerial procedures to safeguard and secure your Personal Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. These measures are appropriate to the risks involved and the nature of the Personal Information.

 

THEMIS may be required to disclose your Personal Information in response to lawful request by public authorities, including to meet national security or law enforcement requirements. If so, THEMIS will do so in a manner that is consistent with this Privacy Policy. THEMIS cannot guarantee the security of Information on or transmitted via the Internet.

 

  1. Data Integrity and Purpose Limitation

THEMIS shall only process and uses Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized. To the extent necessary for those purposes, THEMIS shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

 

  1. Access – Corrections/Information Removal/Opt-Out.

THEMIS acknowledges the right of individuals generally to access their Personal Information. THEMIS shall allow an individual access to their Personal Information by contacting THEMIS using the contact information provided below to confirm whether their Personal Information is being processed, as well as whether the Personal Information is accurate and whether THEMIS is processing it lawfully. THEMIS shall also allow the individual to amend or delete inaccurate information.

 

THEMIS may charge a reasonable fee for access, and it will respond to any request for access within a reasonable time and in a reasonable manner. THEMIS may restrict access to Personal Information in exceptional circumstances where the legitimate rights of persons other than the individual would be violated or where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy. THEMIS may also deny access where it could reveal confidential commercial information, such as trade secrets.

 

THEMIS may not retain all Personal Information it collects, which may impact requests for access. Additionally, access may be restricted where disclosure would interfere with national security, defense, public security, or research.

 

  1. Compliance with the EU-US and Swiss-US Privacy Shield Frameworks.

THEMIS complies with the EU-U.S. Privacy Shield Framework and 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.  THEMIS has certified to the Department of Commerce that it adheres to the Privacy Shield Principles (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/.

 

  1. Recourse, Enforcement and Liability

THEMIS uses a self-assessment approach to assure 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. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

 

THEMIS has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks to an independent dispute resolution mechanism 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 https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

 

Under certain limited conditions, you may also have the right to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission or Swiss Government.

 

Our commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

 

  1. Contact Us.

Questions or comments or complaints regarding THEMIS’s Privacy Policy or compliance with EU-US or US-Swiss Privacy Shield Frameworks or data collection and processing practices can be mailed or emailed to:

 

Themis North America Inc., a QuintilesIMS Company

Attn: Legal Department

83 Wooster Heights Road

Danbury, CT 06810

info@themisanalytics.com