PRIVACY POLICY

Medmeme Privacy Policy
Effective January 1, 2016.

EU-U.S. Privacy Shield and U.S.-Swiss Safe Harbor Compliance
Medmeme, LLC is a participant in the U.S. Department of Commerce’s EU-U.S. Privacy Shield and has certified that we adhere to the EU-U.S. Privacy Shield Principles. Medmeme, LLC is subject to the investigatory and enforcement powers of the Federal Trade Commission. For more information about the EU-U.S. Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website at https://www.privacyshield.gov

SCOPE
This Policy applies to all personal information received by Medmeme, LLC in the United States from the EEA in any format, including electronic, paper or verbal. Medmeme respects individual privacy and values the confidence of its customers, employees, business partners and others. Medmeme does not collect, use and disclose personal information. Medmeme does not use any third party agencies to collect personal information. All information collected by Medmeme comes from credible public sources available in public domain on the internet. Not only does Medmeme comply with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices.

DEFINITIONS
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Medmeme or to which Medmeme discloses personal information for use on Medmeme’s behalf.
“Medmeme” means its successors, subsidiaries, divisions and groups in the United States.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of Medmeme 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, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, Medmeme will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES
The privacy principles in this Policy have been developed based on the Privacy Shield Principles.

  1. Medmeme does not collect private information
  2. Medmeme does not intentionally collect information from under 13’s
  3. Medmeme does not conduct any internet financial transactions
  4. Any Private information that is collected unintentionally is deleted from Medmeme’s databases as soon as such information is discovered through internal data audit.
  5. Any user information collected by Medmeme will remain in Medmeme’s database

NOTICE: In case Medmeme were to collect personal information directly from individuals in the EEA, 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 Medmeme discloses that information, the choices and means, if any, Medmeme offers individuals for limiting the use and disclosure of personal information about them, and how to contact Medmeme. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Medmeme, or as soon as practicable thereafter, and in any event before Medmeme uses or discloses the information for a purpose other than that for which it was originally collected.

Where Medmeme receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose 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: Medmeme 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, Medmeme 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. Medmeme will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY: Medmeme will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Medmeme will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS: In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Medmeme, LLC remains liable

Medmeme will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Privacy Shield Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Privacy Shield certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where Medmeme has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Medmeme will take reasonable steps to prevent or stop the use or disclosure

ACCESS AND CORRECTION: Upon request, Medmeme will grant individuals reasonable access to personal information that it holds about them. In addition, Medmeme will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY: Medmeme will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Medmeme does not use cookies, only authorized users who have secure username and password are allowed to view the data.

ENFORCEMENT: Medmeme will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Medmeme determines is in violation of this policy 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 Medmeme Privacy Office at the address given below. Medmeme will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between Medmeme and the complainant, Medmeme has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Privacy
Shield Principles:

  1. for disputes involving all personal information received by Medmeme from Switzerland, Medmeme has agreed and to cooperate with the Swiss FDPIC;
  2.  for disputes involving employment-related personal information received by Medmeme from the EEA, Medmeme has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;
  3. for disputes involving all other personal information received by Medmeme from the EEA, Medmeme has agreed to eTRUST dispute resolution. Individuals who submit a question or concern to Medmeme and who do not receive acknowledgment from Medmeme of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the eTRUST Privacy Shield Dispute Resolution Program on the Internet, by mail or by fax. Inquiries by mail or fax should identify Medmeme as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether eTRUST may share the details of the inquiry with Medmeme. eTRUST will act as a liaison to Medmeme to resolve these disputes.
  4. Fax: 1-212-725-5993
  5. Mail: Medmeme LLC, 501 7th Avenue, Suite 508, New York, NY 10018
  6.  http://www.etrust.org/cert/867656.html
  7. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, you can also submit your complaint to Privacy Trust, an independent third party. Visit https://www.privacytrust.com/drs/medmeme to file a complaint.
  8. Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by Medmeme to these Privacy Shield Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

CONTACT INFORMATION
Questions or comments regarding this Policy should be submitted to the Medmeme Corporate Office by mail as follows:

Medmeme, LLC
501 7th Avenue, Suite 508
New York, NY 10018

Attn: Data Privacy Officer/Privacy Shield

CHANGES TO THIS PRIVACY SHIELD PRIVACY POLICY
This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield Principles. A notice will be posted on the Medmeme web page (www.medmeme.com) for 60 days whenever this Privacy Shield Privacy Policy is changed in a material way.

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