Safe Harbor Privacy Policy

Version 2.2 Revised: 04/24/2015

Parallel 6 respects individual privacy and is committed to maintaining the privacy and security of personal information of our clients, employees, partners and others. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles that Parallel 6 follows with respect to transfers of personal information between member states of the European Economic Area (“EEA”) and the United States, and Switzerland and the United States.

Scope

This Policy applies to all personal information received by Parallel 6 in the United States from the EEA and/or Switzerland in any format including electronic or hard copy.

Definitions

“Personal information” means any information or set of information that identifies or is used by or on behalf of Parallel 6 to identify an individual. It does not include information that has been encoded, made anonymous or, otherwise stripped of its identifiers, nor does it include publicly available information unless combined with other non-public personal information.

“Sensitive personal information” means personal information that reveals race, ethnic origin, political or religious beliefs or personal information regarding health conditions.

Privacy Policy

The privacy principles in this policy are based on the seven Safe Harbor Principles. Parallel 6 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. Parallel 6 has certified that it adheres to the seven Safe Harbor Privacy Principles of notice, choice, onward transfer, access, security, data integrity, and enforcement. To learn more about the Safe Harbor program, and to view Parallel 6’s certification, please visit http://www.export.gov/safeharbor/.

Notice

When Parallel 6 directly collects personal information from individuals in the EEA, it will (1) disclose the purpose for collecting and using the personal information, (2) describe the types of entities to which disclosures may be made, (3) describe the choices and means, if any, offered by Parallel 6 to individuals to limit the use and disclosure of information and (4) provide contact information to individuals where their inquiries or complaints can be addressed. Notice will be provided when individuals are first asked to provide personal information.

Choice

Parallel 6 will offer individuals the opportunity to opt-out of further uses or disclosures when their personal information is disclosed to a non-agent third party or in connection with a purpose other than the purposes for which it was originally collected or authorized by the individual. If the use or disclosure involves sensitive information, Parallel 6 will afford individuals the opportunity to explicitly opt-in to such use or disclosure when the sensitive information would be disclosed to a non-agent third party or in connection with a purpose other than the purposes for which it was originally collected or authorized by the individual.

Onward Transfer (Transfers to Third Parties)

Before transferring personal information to any third party, Parallel 6 will obtain adequate assurances from its agents and other business partners that they safeguard personal information in a manner consistent with this policy.

Access (To Personal Information)

Parallel 6 will grant individuals reasonable access to their personal information held by Parallel 6, unless such access would compromise the purpose for which it was collected such as blinded clinical research data during a trial. Parallel 6 will take reasonable steps to assist individuals with correcting, amending or deleting personal information that is determined to be inaccurate or incomplete.

Security

Parallel 6 will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Data Integrity

Parallel 6 will use personal information in its possession only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Parallel 6 will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

Enforcement

Parallel 6 will verify its adherence to this Policy by conducting routine compliance audits of its relevant privacy practices. Parallel 6 will take appropriate disciplinary action, consistent with applicable laws, against any Parallel 6 employee who willfully violates or seeks to circumvent this Policy or who takes an action to compromise the integrity or safety of personal data.

Limitation On Application Of Principles

Adherence by Parallel 6 to these Safe Harbor Principles may be limited to the extent (1) required to respond to a legal or ethical obligation, or (2) expressly permitted by an applicable law, rule or regulation, such as processing data specifically requested by government agencies for the purpose of medical safety.

Contact Information

Any contact regarding this Policy should be submitted to Parallel 6 to:

safeharbor@parallel6.com

Changes To This Safe Harbor Privacy Policy

This Policy may be amended from time to time, consistent with the requirements of the U.S.-EU Safe Harbor Principles. Parallel 6 will undertake annual self-certification in compliance with the Safe Harbor requirements for continued registration.

Safe Harbor Privacy Policy – Effective Date: April 1, 2014