Our Safe Harbor Policy
The following information is a declaration of pOrbis Group Inc., and all its wholly-owned U. S. subsidiaries and affiliates (hereafter “pOrbis” or “we”) including pOrbis 3P Consulting Group LLC. To review the overall pOrbis Privacy Policy please click to the following link, as this section outlines the pOrbis Safe Harbor Policy topic only.
Compliance
pOrbis Group, Inc. complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. pOrbis Group, Inc. 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 to view pOrbis Group, Inc.’s certification, please visit http://www.export.gov/safeharbor/.
Scope
This Safe Harbor Privacy Policy (the “Policy”) applies to all personal information received by pOrbis in the United States from the EU, in any format including electronic, paper or verbal.
Definitions
"Personal information" means any information or set of information that identifies or is used by or on behalf of pOrbis 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, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual’s health. In addition, pOrbis will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, pOrbis or to which pOrbis discloses personal information for use on its behalf.
Privacy Principles
The privacy principles in this Policy are based on the Safe Harbor Principles.
Notice
Where pOrbis collects personal information directly from individuals, 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 pOrbis discloses that information, and the choices and means, if any, pOrbis offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear language when individuals are first asked to provide personal information to pOrbis, or as soon as practicable thereafter, and in any event before pOrbis uses or discloses the information for a purpose other than that for which it was originally collected.
Where pOrbis receives personal information from its subsidiaries, affiliates or other entities in the United States, 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
pOrbis offers 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, pOrbis will give individuals the opportunity to affirmatively and explicitly consent (opt-in) 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.
pOrbis will provide individuals with reasonable mechanisms to exercise their choices.
DATA INTEGRITY
pOrbis will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. pOrbis will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
Transfers to Agents
pOrbis will obtain assurances from its agents that they will safeguard personal information consistent 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 Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Hungary and Switzerland). Where pOrbis has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, pOrbis will take reasonable steps to prevent or stop the use or disclosure.
Access and Corrections
Upon request, pOrbis will grant individuals reasonable access to personal information that it holds about them. In addition, pOrbis will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
Security
pOrbis will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Enforcement
pOrbis will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that pOrbis 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 pOrbis at the address given below. pOrbis will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. We, pOrbis Group, Inc., cooperate and comply with the EU Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to investigate unresolved complaints.
Limitation on Application Principles
Adherence by pOrbis Pharmaceuticals to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent expressly permitted by an applicable law, rule or regulation and (c) to the extent necessary to meet national security, public interest or law enforcement obligations.
Effective Date and Changes to our Policy
The effective date of this Safe Harbor policy is March 2014. It was last modified in April 2014. If we decide to change our policy, we will post those changes on this page and update the policy modification date.
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Contact Information
Questions or comments regarding this Policy should be submitted to the pOrbis Corporate Office by mail as follows:
pOrbis Group, Inc / pOrbis 3P Consulting Group LLC
Attn. Executive Management / Legal Department
29226 Orchard Lake Rd, #290
Farmington Hills, MI 48334
Tel: +1-734-6060-800
Email: [email protected]
Compliance
pOrbis Group, Inc. complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. pOrbis Group, Inc. 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 to view pOrbis Group, Inc.’s certification, please visit http://www.export.gov/safeharbor/.
Scope
This Safe Harbor Privacy Policy (the “Policy”) applies to all personal information received by pOrbis in the United States from the EU, in any format including electronic, paper or verbal.
Definitions
"Personal information" means any information or set of information that identifies or is used by or on behalf of pOrbis 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, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual’s health. In addition, pOrbis will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, pOrbis or to which pOrbis discloses personal information for use on its behalf.
Privacy Principles
The privacy principles in this Policy are based on the Safe Harbor Principles.
Notice
Where pOrbis collects personal information directly from individuals, 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 pOrbis discloses that information, and the choices and means, if any, pOrbis offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear language when individuals are first asked to provide personal information to pOrbis, or as soon as practicable thereafter, and in any event before pOrbis uses or discloses the information for a purpose other than that for which it was originally collected.
Where pOrbis receives personal information from its subsidiaries, affiliates or other entities in the United States, 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
pOrbis offers 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, pOrbis will give individuals the opportunity to affirmatively and explicitly consent (opt-in) 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.
pOrbis will provide individuals with reasonable mechanisms to exercise their choices.
DATA INTEGRITY
pOrbis will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. pOrbis will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
Transfers to Agents
pOrbis will obtain assurances from its agents that they will safeguard personal information consistent 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 Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Hungary and Switzerland). Where pOrbis has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, pOrbis will take reasonable steps to prevent or stop the use or disclosure.
Access and Corrections
Upon request, pOrbis will grant individuals reasonable access to personal information that it holds about them. In addition, pOrbis will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
Security
pOrbis will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Enforcement
pOrbis will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that pOrbis 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 pOrbis at the address given below. pOrbis will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. We, pOrbis Group, Inc., cooperate and comply with the EU Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to investigate unresolved complaints.
Limitation on Application Principles
Adherence by pOrbis Pharmaceuticals to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent expressly permitted by an applicable law, rule or regulation and (c) to the extent necessary to meet national security, public interest or law enforcement obligations.
Effective Date and Changes to our Policy
The effective date of this Safe Harbor policy is March 2014. It was last modified in April 2014. If we decide to change our policy, we will post those changes on this page and update the policy modification date.
.
Contact Information
Questions or comments regarding this Policy should be submitted to the pOrbis Corporate Office by mail as follows:
pOrbis Group, Inc / pOrbis 3P Consulting Group LLC
Attn. Executive Management / Legal Department
29226 Orchard Lake Rd, #290
Farmington Hills, MI 48334
Tel: +1-734-6060-800
Email: [email protected]
