Quadax Safe Harbor Privacy Policy

We self-certify compliance with

Quadax respects individual privacy and is committed to providing the highest level of privacy as it relates to the use of patient information.  This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that Quadax follows with respect to transfers of personal information from the European Economic Area (EEA) or Switzerland to the United States (US).

This Policy applies to all personal information received by Quadax in the US from the EEA (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and to Switzerland.  For the most part, that personal information pertains to our client’s patients.

Definitions

The following definitions shall apply throughout this Policy:

"Agent" means any third party that uses personal information provided to Quadax to perform tasks on behalf of and under the instructions of Quadax.

"Quadax" means Quadax Corporation, its subsidiaries, divisions, and business units in the US.

"Personal Information" means any information or set of information that identifies an individual, or could be used by or on behalf of Quadax to identify an individual.

“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

Privacy Principles

Quadax 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.  Quadax 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 Quadax’s certification, please visit www.export.gov/safeharbor.

Notice

When Quadax collects personal information directly from individuals in the EU and Switzerland, it will inform them about the purposes for which it collects and uses their personal information and the types of agent, if any, to which Quadax discloses that information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Quadax, or as soon as practicable thereafter, but in any event before Quadax uses the information for a purpose other than that for which it was originally collected.

If Quadax receives personal information from its subsidiaries, affiliates or other entities in the EU or Switzerland, it will use such information in accordance with the notices such entities provided and the consents or choices made by the individuals to whom such personal information relates.

Any inquiries or complaints regarding the use or disclosure of personal information should be reported to Quadax’s Privacy Officer at Privacy@Quadax.com.

Choice

Quadax will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party (unless allowed or required by contract), or (b) to be used for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, Quadax will give individuals the opportunity to affirmatively and explicitly consent (e.g., through an opt-in) (a) to the disclosure of the information to a non-agent third party, or (b) to the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Quadax will provide individuals with reasonable methods to exercise their choices.

Data Integrity

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

Onward Transfer

Quadax will obtain satisfactory assurances, in writing, from its agents that they will safeguard personal information consistently with this Policy or are subject to law providing the same level of privacy protection.

Access

Upon request, Quadax will grant individuals reasonable access to the personal information that it holds about them and Quadax will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate.

Data Security

Quadax will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Quadax has put in place appropriate administrative, technical, and physical safeguards in place to protect sensitive personal information.

Enforcement

Quadax will conduct compliance reviews of its relevant privacy practices to verify adherence to this Policy. Any employee that Quadax 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 Quadax Privacy Officer at the address given below. Quadax 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. For complaints that cannot be resolved between Quadax and the complainant, Quadax has agreed to participate in the dispute resolution procedures of the panel established by the European Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner to resolve disputes pursuant to the Safe Harbor Principles.

Contact Information

Questions or comments regarding this Policy should be submitted to:
Compliance Officer
Quadax, Inc.
7500 Old Oak Blvd
Cleveland, OH 44130
Email: Privacy@Quadax.com

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Quadax will provide appropriate notice about such amendments.

Effective April 12, 2011
Revised August 22, 2012