At Scarritt Group, Inc.” Scarritt” we are committed to safeguarding the privacy of our customers. We will never sell, release, or transmit customer information externally for any purpose other than with approved business partners in secure circumstances, and only then for the benefit of creating successful experiences for our clients. All internal information is gathered and retained only for the duration of retained services, except as defined by regulatory requirements, and then based upon the regulatory retention period and/or client request for data archival.

The Privacy Statement describes how we collect, use, protect, and disclose the Personal Information you share with us online and offline unless otherwise provided pursuant to an informed consent signed by you. Scarritt websites that display this Privacy Statement are committed to only collecting, maintaining, and securing your Personal Information in accordance with the terms of this statement. We encourage you to read this Privacy Statement before submitting any information. By using any Scarritt website, portal or services, submitting or requesting information, you acknowledge that you understand and agree with the provisions of this Privacy Statement.

Scarritt Group works with our clients in the Research and Pharmaceutical industry to provide Logistics, Event Management, and planning for clinical trials. We collect and process personal data for the sole purpose of providing our clients with information and services, including, but not limited to, Available Service Menus, Request for Information or Proposal, Conference Registration, Travel Arrangements, Virtual Conference Center Access, Informational Portals, Learning Management Systems, Patient Recruitment, and Patient Concierge.  Personal data will be transferred only to third parties directly involved in the fulfillment of Pharmaceutical Logistics, Event Management, and planning for our customers and for that specific purpose only. These third parties include (but are not limited to) airlines, hotels, transportation services, and other related service providers. We respect the privacy of your personal information (any information related to an identified or identifiable individual), and we only collect volunteered information and then only in relation to the provided service to the client.

In the course of providing its Services, Scarritt Group may collect, use, store, and disclose personal data. Personal data is any information that can be used to identify you or that we can link to you. You, the user of the Services, may be asked to provide certain personal data when you use our Services, such as:

• Name
• Position title
• Company
• Address
• Phone number
• Email address
• Registration information
• Banking such as IBAN information for reimbursement purposes

When Scarritt collects Consumer Personal Data in its role as a Controller, Scarritt generally offers the relevant Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the DPF Principles, Scarritt shall obtain opt-in consent for certain uses and disclosures of Sensitive Data. These Consumers may contact Scarritt as indicated below regarding Scarritt’s use or disclosure of their Personal Data. Unless Scarritt offers these Consumers an appropriate choice, Scarritt uses Personal Data only for purposes that are materially the same as those indicated in this Policy.

When Scarritt obtains Consumer Personal Data in its role as a Processor for its Customers, Scarritt’s Customers are responsible for providing appropriate notice to its Consumers and ensuring it provides the relevant Consumers with certain choices with respect to the Customers’ use or disclosure of the Consumers’ Personal Data.

Scarritt shares certain Consumer Personal Data with its affiliates and subsidiaries. Scarritt may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data: (i) to third-party Processors Scarritt has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from governmental authorities, including to meet national security, governmental interest or law enforcement requirements. Scarritt also reserves the right to transfer Consumer Personal Data in the event of an audit or if Scarritt sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

To the extent Scarritt acts as a Controller, except as permitted or required by applicable law, Scarritt shall provide Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. Scarritt requires third-party Controllers to whom it discloses such Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the DPF Principles, and (iii) notify Scarritt and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the DPF Principles.

With respect to transfers of Consumer Personal Data to third-party Processors, Scarritt (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the DPF Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Scarritt’s obligations under the DPF Principles, (v) requires the Processor to notify Scarritt if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. Scarritt remains liable under the DPF Principles if Scarritt’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the DPF Principles, unless Scarritt proves that it is not responsible for the event giving rise to the damage.

Where permitted by law, non-Personal Information and data may be automatically collected through the standard operation of Scarritt’s Internet service or through the use of “cookies” or “internet tags” and other similar techniques. This type of anonymous information allows Scarritt to evaluate customer interest in its websites and perform other market research activities. Cookies are small text files a website can use to recognize repeated usage, facilitate the user’s access to and use of the site, and allow a site to track usage behavior and compile aggregate data that will allow content improvement and targeted advertising. Cookies are programs that come into a user’s system but do not damage files. Generally cookies work by assigning a unique number to the user that has no meaning outside the assigning site. If a user does not want information to be collected through the use of cookies, there is a simple procedure in most browsers that allows the user to deny or accept the cookie feature; however, users should note that cookies may be necessary to provide the user with certain features (e.g., customized delivery of information) available on Scarritt’s websites. Scarritt also may collect and store the name of the domain and host from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browser software you use and your operating system; the date and time you access our website; the Internet address of the website from which you linked directly to our website.

Some web browsers that you use may transmit “do-not-track” signals to websites with which the browser communicates. As of the Effective Date of this Privacy Statement, an industry standard on how to respond to these signals has not yet been established. Since industry standards are still evolving, Scarritt will not separately respond to or take any action with respect to “do-not-track” configurations in your internet browser. Scarritt will reassess its approach based upon future procedures, but will respond with similar guidelines, based upon only gathering information based upon providing services to existing clients.

Scarritt Group has established a privacy program designed to help respect and protect your data privacy rights. We maintain administrative, technical, and physical safeguards intended to protect against the loss, misuse, unauthorized access, alteration, or disclosure of Personal Information and Collected Sensitive Personal Information. Although we take such precautions seriously, it is impossible for us to guarantee the safety and security of Personal Information or Collected Sensitive Personal Information. We cannot ensure or warrant the security of any information.

We reserve the right to retain any Personal Data as long as the Personal Data is needed to: fulfill the purposes that are described in above (Why and how we collect data) and comply with applicable law.

Scarritt Group websites are not directed or intended for children. The services offered on our websites are designed for individuals who are 18 years of age or older. If your child has submitted Personal Information and you would like to request that such information be removed, please contact privacyofficer@Scarrittgroup.com. For more information about protecting the privacy of children online in the United States under the Children’s Online Privacy Protection Act, please see http://www.ftc.gov/ogc/coppa1.htm (last accessed January 2013).

Many of Scarritt’s websites may contain links or references to third-party websites as a convenience to you. This Privacy Statement does not cover the practices of these websites. Accessing these sources requires that you leave Scarritt’s websites. Scarritt does not control the content of these third-party websites and is not responsible for their privacy practices. Please review the privacy policies on each website that you visit.

If you would like to access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Data collected via the Scarritt Group, you may submit a request to privacyofficer@Scarrittgroup.com).

The foregoing terms are effective as of May 25, 2018. Scarritt may update this Privacy Statement from time to time based on, among other things, changes in applicable laws, the development of new websites, and technological advances. Scarritt reserves the right to modify, add, or remove portions of this Privacy Statement at any time at our sole discretion. If we decide to revise this Privacy Statement, we will post the revised Privacy Statement at this site. We encourage you to review the Privacy Statement each time you visit our site. This Privacy Statement is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

Scarritt has mechanisms in place designed to help assure compliance with the DPF Principles. Scarritt conducts an annual self-assessment of its Personal Data practices to verify that the attestations and assertions Scarritt makes about its DPF privacy practices are true and that Scarritt’s privacy practices have been implemented as represented and in accordance with the DPF Principles.

Scarritt Group, Inc. “Scarritt” respects Consumers’ concerns about privacy. Scarritt complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) (EU-U.S. DPF, UK Extension and the Swiss-U.S. DPF, collectively, the “DPF”) as set forth by the U.S. Department of Commerce. Scarritt has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Scarritt has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles,” and together with the EU-U.S. DPF Principles, the “DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. This Policy describes how Scarritt implements the DPF Principles for Consumer Personal Data.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Scarritt commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Scarritt using the contact information in the “How to Contact” section of this policy.

If a Consumer’s complaint cannot be resolved through Scarritt’s internal processes, Scarritt will cooperate with JAMS pursuant to the JAMS DPF Program, which is described on the JAMS website at https://www.jamsadr.com/eu-us-data-privacy-framework. JAMS mediation may be commenced as provided for in the JAMS rules. Following the dispute resolution process, the mediator or the Consumer may refer the matter to the U.S. Federal Trade Commission, which has DPF investigatory and enforcement powers. Under certain circumstances, Consumers may also be able to invoke binding arbitration to address complaints about Scarritt’s compliance with the DPF Principles.

If you have any questions about our Privacy Statement, or need to contact us for any other reason, you may email us at privacyofficer@scarrittgroup.com. If you are located in the European Union, you may contact our representative in the European Union by sending an email to DataRep at datarequest@datarep.com quoting “Scarritt Group, Inc.” in the subject line.

If you have a privacy-related concern or complaint, please contact us using the information above, and we will attempt to address your concerns. You may contact the Data Protection Authority in your country  or JAMS if we do not resolve your complaint.

As an International Company, Scarritt Group is committed to adhering to the guidelines and regulations of the areas we serve. General Data Protection Regulation (GDPR) provides additional requirements for the collection and retention of Personal Users data in EU (European Union).

At Scarritt Group we are in the business of selling ourselves to our customers, not selling our customer’s data to others. We do not collect, retain, or use any client data for any other purpose other than to ensure a successful outcome for our client’s meetings. Upon completion of services, data is only retained as specified by regulatory guidelines, and only for the period of time defined, or alternatively, as has been specifically contracted by clients to retain for their archival purposes.

We utilize industry leading Information System Products and enforce Information System Data Protection policies to safeguard all internal Personal Information. Please contact privacyofficer@scarrittgroup.com with any questions or request for information.