This Policy applies to Alere Inc., and all of its wholly-owned subsidiaries and affiliates. References to “Alere” in this policy refer to Alere Inc., and all of its wholly-owned subsidiaries and affiliates. “Personal Information” means any information or set of information that identifies or can reasonably be used to identify an individual (the “Identifiable Person”). “Personal Information” is that defined in Article 4 (1) of Regulation (EU) 2016/679, known as ‘GDPR’ and includes any data that may directly or indirectly identify a natural person. “Special Categories of data” as defined in Article 9 of Regulation (EU) 2016/679 is data that pertains to medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation or any other data that is identified as a “special category of data” under Article 9 of Regulation (EU) 2016/679.
Purposes of Collection of Personal Information
Use of Alere Image is to be entirely at the discretion of the Data Controller and Alere will act on behalf of the Controller in accordance with any agreements and will only process data on the basis of legal agreement or by written instructions from Data Controllers.
Privacy Shield Framework
Alere complies with the EU-US Privacy Shield 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. Alere has certified that it adheres to the Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the EU-US Privacy-Shield, and to view Alere’s certification, please visit https://www.privacyshield.gov.
At the time that Alere collects Personal Information from you for any of the purposes identified above, we will inform you of the purpose for which the Personal Information is being collected and used, and how to contact Alere with any questions or complaints, or to update your Personal Information. Alere will not disclose Personal Information to third parties except in accordance with this Policy and as disclosed at the time of the collection of the Information.
Alere will fully inform you and request consent where Personal Information is to be (a) disclosed to a third party or (b) used for a purpose other than that for which the Personal Information was originally collected or subsequently authorized by you. Alere will not disclose Special categories of data to a third party or use it for any purpose other than that for which it was originally collected or subsequently authorized by you, except as required by law, court order, or subpoena.
Taking into account the nature of the information processing, the cost of implementation and the risks to the rights and freedoms of the data subjects, Alere will take all appropriate technical and organisational measures to keep your Personal Information secure. All personally identifiable information is subject to restricted access to prevent unauthorized processing.
Alere will not process your Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently consented by you. To the extent necessary for those purposes, Alere will take appropriate technical and organisational measures to ensure that Personal Information is collected lawfully and transparently, relevant for its intended use, accurate, complete and current.
Under Regulation (EU) 2016/679 data subjects have a comprehensive set of rights with respect to their personal information and Alere has mechanisms established to receive, assess and enact these rights on request from data subjects. These rights include:
- The right to erasure of your data (the right to be forgotten).
- The right to object (the right to have us stop using your data for a specified purpose)
- The right to amendment (the right to have incorrect data amended)
- The right to access (to be given a copy of all the data we hold on you in a portable format)
- The right to the restriction of processing (to restrict the use of your data)
- Rights related to automated processing (we do not conduct any automated processing)
These rights can be exercise by contacting Alere using the email address firstname.lastname@example.org or contacting the Alere Data Protection Officer at Privacy Officer, Alere Inc., 51 Sawyer Road, Suite 200, Waltham, MA 02453.
Transfer to Third Parties
Where it has been established that it is lawful to do so, and information has been provided to the data subject, and before Alere transfers Personal Information to a third party that is acting as an agent, it will ascertain that the third party safeguards Personal Information consistent with this policy, has itself made a Privacy Shield self-certification, or is subject to the EU Data Protection Directive and this relationship will be governed by a legally binding agreement to ensure that the terms of Regulation (EU) 2016/679 are fully complied with.
Alere will conduct periodic internal audits to our ongoing adherence to this Policy, and will promptly seek to remedy any instances of noncompliance brought to its attention.
We encourage individuals covered by this Policy to raise any concerns that they have about the way that we protect and process their Personal Information by contacting email@example.com or Ethics Compliance Officer, Alere Inc., 51 Sawyer Road, Suite 200, Waltham, MA 02453, and we will do our best to resolve them. Alere will investigate your concerns promptly, and will respond to your correspondence within thirty (30) days after we receive it. Alere will provide you with a clear explanation of any decisions made with respect to your request.
For complaints that cannot be resolved between you and Alere
(b) If you are a resident of the European Union and have provided Personal Information in connection with an employment relationship with Alere, Alere has agreed to participate in the dispute resolution program provided by the European Data Protection Authorities Panel pursuant to the Privacy Shield principles. Any Natural Person who is resident in the EU should address his or her concerns to his or her local data protection authority or Supervisory Authority.
Information Collected on Our Websites
When you supply Personal Information on Alere Image, we will use it for the express purpose for which it was collected. At any time, however, you may opt out of such future contact by writing us at firstname.lastname@example.org or Privacy Officer, Alere Inc., 51 Sawyer Road, Suite 200, Waltham, MA 02453.
Limitation on Scope of Principles
Please note that we will release your Personal Information if required to do so by law, or by search warrant, subpoena, or court order.
Changes to this Policy
This Policy may be amended from time to time, consistent with the requirements of the EU-US Privacy Shield Framework or other relevant data protection regulations. When we do amend it, we will also revise the “last updated” date at the bottom of this Policy.
20th June 2018