Privacy Statement

Revised as of July 5, 2017

Thank you for your trust in TRIEVR Data Services, Inc. and for taking the time to read our Privacy Statement. This Privacy Statement tells you how we protect the privacy of personal information that you may provide to us.

EU-U.S. and Swiss-U.S. Privacy Shield

As part of our commitment to privacy, TRIEVR complies with and has voluntarily certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks 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, respectively.

TRIEVR has certified that it 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. To learn more about the Privacy Shield Framework, visit U.S. Department of Commerce’s Privacy Shield List. . If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

TRIEVR is responsible for the processing of personal data it receives, under the Privacy Shield Frameworks, and subsequently transfers to a third party acting as an agent on its behalf. TRIEVR complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, respectively, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, TRIEVR is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, TRIEVR may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, TRIEVR commits to resolve complaints about your privacy and our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact TRIEVR at PrivacyQuestions@TRIEVR.com.

TRIEVR has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to BBB EU Privacy Shield, a non-profit alternative dispute resolution provider located in the United State and 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. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration before a Privacy Shield Panel when other dispute resolution procedures have been exhausted.

General Information on Privacy

The term “personally identifiable information” as used in this Policy refers to two categories of personal data: General Personally Identifiable Information and Sensitive Personally Identifiable Information. General Personally Identifiable Information: means first and last name, birth date, gender, e-mail address, mailing address, profession, education, or professional affiliations used to identify you. All other levels of personal information including, but not limited to, religion, race, health status, political opinion, sexual preferences, income, social security number, or credit card numbers, are known as “Sensitive Identifiable Information”, and together, we refer to General Personally Identifiable Information and Sensitive Identifiable Information as simply “personally identifiable information.” TRIEVR will collect and use only as much personally identifiable information as is (i) required by law or (ii) necessary to fulfill the purpose for which the information is collected, as such purposes are detailed in this privacy statement.

Purpose of Privacy Policy

The purpose of this privacy statement is to explain what TRIEVR does with personally identifiable information that you provide to us. We want you to know how your personally identifiable information will be protected, who we may share it with, and for what purposes.

Collection of Your Information

Subscriptions to TRIEVR, require registration. When you register an account, we collect some personally identifiable information, such as your name, phone number, credit card or other billing information, email address and home and business postal addresses. This allows us to send you information that you request or contact you about TRIEVR’S services, subscription billing and support of electronic signatures. You may also ask us to import your contacts by giving us access to your third party services (for example, your email account) or to use your social networking information if you give us access to your account on social network connection services. When you invite others to join TRIEVR by using our invite page, we will send them a one-time email for that referral. You may also provide us with your contacts’ email addresses when assigning task to them. We may also receive personally identifiable information (for example, your email address) through other users, for example if they have tried to assign something with you or tried to refer TRIEVR to you.

TRIEVR limits the collection and processing of personally identifiable information to what is necessary to fulfill the purposes for which it is to be used. We will not review, share, distribute, or reference any such customer data except as provided in the TRIEVR Master Subscription Agreement, or as may be required by law. In accordance with the TRIEVR Master Subscription Agreement, we may access such customer data only for the purposes of providing the services, preventing or addressing service or technical problems, at your request in connection with customer support matters, or as may be required by law.

Retention of Your Information

TRIEVR will retain your information for as long as needed to provide you services. If you cancel your services with us, we may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Consistent with these requirements, we will try to delete your information quickly upon request. Please note, however, that there might be latency in deleting information from our servers and backed-up versions might exist after deletion. In addition, we do not delete from our servers files that you have in common with other users.

HIPAA Privacy Rule

Our programs and services adhere to The Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy and Security Rules. For more information on HIPAA please visit http://www.hhs.gov/ocr/privacy/.

The HIPAA Privacy Rule provides federal protections for personal health information held by covered entities and gives patients an array of rights with respect to that information. At the same time, the Privacy Rule is balanced so that it permits the disclosure of personal health information needed for patient care and other important purposes. The Security Rule specifies a series of administrative, physical, and technical safeguards for covered entities to use to assure the confidentiality, integrity, and availability of electronic protected health information.

Data Integrity

TRIEVR takes reasonable steps to ensure that personal data collected is reliable for its intended use, accurate, complete, and current.

Collection of Anonymous Computer Information

When you visit our websites, we do not collect any personally identifiable information about you without your permission.

Consent to Provide Your Information to TRIEVR

We request your consent to collect your personally identifiable information when you seek to register for a TRIEVR program or service. In doing so, we also explain, for that program or service, what you are registering to receive and how we plan to use your personal information. We also offer you the option of discontinuing your consent (“opting out” or “unsubscribing”) if you later decide that you no longer want to participate in that program or receive additional information from us. If we wish to use this information for purposes incompatible from those for which the data was initially collected, we will offer an effective way to opt out of the secondary use.

Sharing Your Information With Third-Parties

TRIEVR will not share your personal information with third-parties for their own separate use unless we have obtained your opt-in consent to do so.

There may be instances where TRIEVR may be required to share your information with third-parties who have not been retained by us (directly or indirectly), such as with health authorities to report possible adverse drug experiences, during inspections or audits, or as ordered or directed by courts or other governmental agencies. Many entities receiving personally identifiable information under these conditions have privacy requirements that apply to their handling of your information.

Security of Your Information

We use appropriate technical, administrative and physical safeguards to protect data that pertains to you from loss, misuse or alteration. In addition, we take steps to ensure that our safeguards take into account new known threats. Of course, no organization can guarantee the absolute security of personal information. You should keep in mind that Internet transmissions, particularly email transmissions, are never 100% secure or error-free. Accordingly, we also caution you to guard your own computer and password against unauthorized access by others.

We encrypt all data that you upload, including, but not limited to, task comments, contact lists, reach out comments, and uploaded attachments, into our programs using 2048 byte encryption. Your data will only be unencrypted when you login using your secure login and password information.

Transfer of Your Information

When TRIEVR transfers personal information to countries other than the country where the information was provided, we do so in compliance with applicable privacy laws. We protect personal information entrusted to us no matter what country it is stored in or transferred to and have appropriate procedures in place to help ensure the security of your personal information. As noted above, we also adhere to the US Department of Commerce’s Privacy Shield standards concerning the transfer of personal data from the European Union and Switzerland to the United States of America.

Protection of Children

TRIEVR will not knowingly collect, use or disclose personally identifiable information from a minor under the age of 13, without obtaining prior consent from a person with parental responsibility (parent or guardian). TRIEVR abides by the Children’s Online Privacy Protection Act (COPPA) in the United States, and respects similar laws of other countries that are protect the privacy of children. Should a child whom we know to be under 13 provide personally identifiable information to us, we will use that information only to respond directly to that child to inform him or her that we must have parental consent before receiving information about him or her.

Accountability

Our privacy practices are periodically reviewed by our auditors to verify compliance with this Privacy Statement.

Updating and Accessing Your Information

We encourage you to update the information you provide to us, such as providing us with a new mailing or email address, a name change, or a change in the medical conditions that you have notified us about. This will help us continue to provide information to you that best meets your needs.

In addition, TRIEVR complies with laws and regulations applicable to the right to amend your data in our files. These rights are limited in some ways. In addition, in order to protect your data from unauthorized access or alteration by third parties, all requests to update or access your information will be subject to verification of the identity of the requesting individual.

Updated TRIEVR Privacy Policies

This Privacy Statement becomes effective on July 5, 2017. TRIEVR may update this Privacy Statement from time to time. We encourage you to review our Privacy Statement periodically.

How to Contact Us

If you have any questions about our Privacy Statement, please contact PrivacyQuestions@TRIEVR.COM.