AISSEL TECHNOLOGIES, INC.

PRIVACY POLICY AND PRIVACY SHIELD POLICY

EFFECTIVE JUNE 12, 2017

The purpose of this privacy policy (this "Policy") is to provide individuals with a description of the types of information we at Aissel Technologies, Inc. ("we", "Aissel" or the "Company"), collect about individual persons through our products (the "Product") and to confirm that we comply with the US-EU Privacy Shield Framework promulgated by the United States Department of Commerce.

SOURCE OF INFORMATION WE COLLECT

The purpose of this privacy policy (this "Policy") is to provide individuals with a description of the types of information we at Aissel Technologies, Inc. ("we", "Aissel" or the "Company"), collect about individual persons through our products (the "Product") and to confirm that we comply with the US-EU Privacy Shield Framework promulgated by the United States Department of Commerce.

KINDS OF INFORMATION WE COLLECT

In general, we collect the following types of information: contact information, including, a name, work email address, work mailing address, work telephone number, educational and professional background, and information concerning the individual's scientific publications, participation in seminars and similar academic work.

HOW WE USE INFORMATION.

The primary use of the information we collect is to inform our corporate customers of possible business relationships consistent with individual's professional experience and research interests. The third parties to which the Company discloses personal information are in general corporate customers in the health care field (including without limitation pharmaceutical and health care products companies) that desire to have a business relationship building on professional knowledge and experience of qualified individuals.

We also use such information to :

  • respond to inquiries or service requests and monitor such responses;
  • manage and assess usage of the Product;
  • to carry out our obligations arising from any contracts;
  • to administer our Product and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our Product to ensure that content is presented in the most effective manner;
  • as part of our efforts to keep our Product safe and secure; and
  • make suggestions and recommendations to users of our Product about products that may interest them.

Any individual with questions regarding the foregoing, or our privacy practices, or the Product, may contact: support@aissel.com.

DISCLOSURE OF INFORMATION

We do not share personally identifiable information to third parties who are not affiliates of the Company, except as described here. We may disclose personally identifiable information to appropriate affiliates of the Company, including strategic alliance affiliates and third party service providers, to respond to a request for service or to provide information about available products or services. We are not limited in our use of non-personal information that does not permit direct association with any specific individual, or non-identifiable aggregate information about our users (such as the number of users of our Product, the geographic distribution of our users, the amount of information located and/or removed, etc.).

We disclose information that we, in good faith, believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our TOS. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity's contact information to victims who request it. In addition, we reserve the right to disclose aggregate information and personally identifiable information to third parties as required or permitted by law and when we believe that disclosure is necessary to protect our rights.

We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process ("Legal Request"), including Legal Requests from private parties in a civil action, and in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If the Legal Request seeks information about an identified user or limited group of users, we'll make reasonable business efforts to contact the user(s) before providing information to the party that requests it. We cannot guarantee that we will be able to contact the user(s) in all cases, whether because of a time limit, court order, inability to effectively contact a user, or for any other reason. We may disclose information to an individual's agent or legal representative (such as the holder of a power of attorney that an individual grants, or a guardian appointed for an individual).

We share information with companies that provide public relations and marketing services for us. Such information will only be shared by us to customize, measure and improve our products, services and advertising; it will not be shared with third parties for their marketing purposes. These third parties are obligated to protect information under equivalent terms to this Policy and are prohibited from using personally identifiable information for any other purpose.

As with any other business, it is possible that in the future we could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by us, including customer account information, but would continue to be bound by this Policy unless and until it is amended.

We share information with our parent, subsidiaries and joint ventures to help coordinate the Product we provide, enforce our terms and conditions, and promote trust and safety. We may share aggregate truly anonymized (non-personally identifiable) information with certain third parties such as advertisers, national industry organizations, and prospective affiliates.

DATA SECURITY

We follow commercially accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. While we strive to use commercially acceptable means to protect personal information, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee its absolute security. In the event of an inadvertent disclosure of personal information we will take all commercially reasonable steps to limit and remedy the disclosure as required by the applicable law. If individuals have any questions about security regarding our Product, they can contact us at privacy@aissel.com.

RIGHT OF OPT-OUT, ACCESS AND CORRECTION

We provide individuals the opportunity to "opt-out" of having their personally identifiable information collected by us. In addition, European data protection legislation gives individuals the right to access personally identifiable information held about them. Individuals may ensure that such information is accurate and relevant for the purposes for which we collected it. Individuals may review their own information and correct or remove any information that is incorrect, as permitted by applicable law. To request opt-out, review, modification or removal of personal data, you should submit a written request to us at privacy@aissel.com.

EU-US-SWISS PRIVACY SHIELD FRAMEWORK

Aissel complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.

Aissel has certified to the Department of Commerce that we adhere to the Privacy Shield Principles, including those relating to Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. We commit to subject to the Principles all personal data received from the EEA in reliance on the Privacy Shield. These Principles include without limitation (i) the possibility for the individual to invoke binding arbitration and (ii) our liability in the case of onward transfer to third parties. In addition to Aissel, Aissel Technologies Pvt. Ltd., Aissel's parent company. also adheres to the Principles. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, any rights an individual may have to binding arbitration before a Privacy Shield Panel, and to view our certification page, please visit https://www.privacyshield.gov.

In compliance with Privacy Shield Principles, Aissel commits to resolve complaints about privacy and our collection or use of personal information. European Union and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Aissel at privacy@aissel.com.

Aissel further has committed to refer unresolved privacy complaints to JAMS (Judicial Arbitration & Mediation Services), an independent alternative dispute resolution provider located in the United States and recognized for this purpose by the US Department of Commerce. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information, and to file a complaint. The services of JAMS are provided at no cost to the individual.

The Federal Trade Commission has enforcement authority regarding Aissel's compliance with the Privacy Shield Principles.

GOVERNING LAW

This Policy is governed by the laws of the Commonwealth of Massachusetts, U.S.A. without giving effect to any principles of conflict of law.

AGE LIMITATION

The Product is not directed to person under the age of 18. If you become aware that a child has provided us with personal information, please contact us at privacy@aissel.com. We do not knowingly collect or solicit information concerning persons under 18 years old. If we become aware that a person under 18 has provided us with personal information, we take steps to remove such information and terminate the person's account.

EFFECTIVE DATE; POLICY CHANGES

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to individuals by e-mail. Please check back frequently to see any updates or changes to our privacy policy. Our business changes frequently and this Policy is subject to change from time to time. Individuals are encouraged to check the Site regularly for any changes to this Privacy. Unless stated otherwise, our current Policy applies to all information that we have about individuals. We will not materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected individuals.

CALIFORNIA PRIVACY RIGHTS.

California Civil Code Section 1798.83 permits customers who are California residents and who have provided the Company with "personal information" (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a California resident with questions regarding this, please contact us at privacy@aissel.com.

CONTACT US

To contact us with your questions or comments regarding this Policy or the information collection and dissemination practices of the Product, please email us at privacy@aissel.com. All trademarks, service marks, and other proprietary materials herein are the property of the Company or its affiliates. All rights reserved.