Privacy Shield Policy IDP01-001-001 V01

Applicability date: 08/14/2019

Privacy Shield Policy - IDP01-001-001 V01

Applicability date: 08/14/2019

This Privacy Shield Policy ("Policy") describes how HalioDx, Inc. (“HalioDx”) collects, uses, and discloses certain personally identifiable information from patients, employees, and customers (“Personal Data”) that we receive in the US from the European Economic Area ("EEA"). This Policy supplements our Website Privacy Policy located at https://www.haliodx.com/privacy-policy/ and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website Privacy Policy.

HalioDx recognizes that the Privacy Shield Framework provides a method for companies to transfer personal data to the United States from the EEA in a way that is consistent with EU law. In order to comply with the Privacy Shield Principles. HalioDX has established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EEA. To provide adequate protection for certain Personal Data about patients, corporate customers, clients, suppliers, business partners, job applicants, and employees received in the US from the EEA, HalioDx has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce ("Privacy Shield"). HalioDx adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.

For purposes of enforcing compliance with the Privacy Shield, HalioDx is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce's Privacy Shield website located at: https://www.privacyshield.gov. To review HalioDx's representation on the Privacy Shield list, see the US Department of Commerce's Privacy Shield self-certification list located at: https://www.privacyshield.gov.

Personal Data Collection and Use

HalioDx is a Clinical Laboratory Improvement Amendments (“CLIA”) clinical laboratory which distributes amongst its affiliated entities immune-based diagnostic products to guide cancer care and contribute to precision medicine in the era of immuno-oncology and combination therapies. HalioDx may receive the following categories of Personal Data in the US: identification data, contact data, financial data, transaction data, technical data, location data, marketing and communications data, profile data and pseudonymous data. HalioDx processes Personal Data for the following purposes: human resource management, management of biological samples, clinical data, routine diagnostic activities, testing service activities, internal HalioDx development, consortia, and medical affairs projects; HalioDx will only process Personal Data in ways that are compatible with the purpose that HalioDx collected it for, or for purposes the individual later authorizes. Before we use Personal Data for a purpose that is materially different than the purpose we collected it for or that is later authorized, the company will provide interested parties with the opportunity to opt out. HalioDx maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.

HalioDx may collect the following categories of sensitive Personal Data: genetic data, biometric data, and health data. The company processes sensitive Personal Data for the following purposes: management of biological samples, routine diagnostic activities, testing service activities, internal HalioDx development, consortia, and medical affairs projects.

When HalioDx collects sensitive Personal Data, it will obtain interested parties’ opt-in consent where the Privacy Shield requires, including if it discloses sensitive Personal Data to third parties, or before it uses sensitive Personal Data for a different purpose than it collected it for or than subjects later authorized.

Data Transfers to Third Parties

Third-Party Agents or Service Providers. HalioDx does not transfer Personal Data to third-party agents and service providers.

Transfers to HalioDx Affiliates. If HalioDx transfers Personal Data to one of its affiliated entities, it will take steps to ensure that such Personal Data is protected with the same level of protection the Privacy Shield requires.

Disclosures for National Security or Law Enforcement. Under certain circumstances, HalioDx may be required to disclose Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security

HalioDx maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

Access Rights

If HalioDx has collected your Personal Data, you may have the right to access such Personal Data that it holds about you and to request that the company correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or xpensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. HalioDx may request specific information to confirm your identity. In some circumstances. the company may charge a reasonable fee for access to your information.

Questions or Complaints

In compliance with the EU-US Privacy Shield Principles, HalioDx commits to resolve complaints about privacy and its collection or use of Personal Data. HalioDx further commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to unresolved Privacy Shield complaints concerning data transferred from the EU. Individuals with inquiries or complaints regarding this Policy should first contact HalioDx at: privacy@haliodx.com.

HalioDx has further committed to refer unresolved privacy complaints under the EU-US Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, 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 www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Binding Arbitration You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps:

  • (1) raised your compliant directly with HalioDx and provided us the opportunity to resolve the issue;
  • (2) made use of the independent dispute resolution mechanism identified above; and
  • (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you.

For more information on binding arbitration, see US Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration).

Contact Us

Questions about this Policy or requests to access to Personal Data should be addressed to privacy(at)haliodx(dot)com.

Changes To This Policy

We reserve the right to amend this Policy from time to time consistent with the Privacy Shield's requirements.