Safe Harbor Privacy Policy

This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that our company follows with respect to transfers of Personal Information from the European Economic Area ("EEA") (which includes the fifteen member states of the European Union ("EU") plus Iceland, Liechtenstein and Norway) to the United States.

1. Safe Harbor

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to Personal Information transferred from the EU to the United States. The EEA also has recognized the U.S. Safe Harbor as providing adequate data protection (OJL 45, 15.2.2001, p. 47). Consistent with its commitment to protect personal privacy, our company adheres to the Safe Harbor Principles.

2. Scope

This Policy applies to all Personal Information received by our company in the United States from the EEA in any format, including electronic, paper or oral.

3. Definitions

For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that uses Personal Information provided by our company to perform tasks on behalf of and under the instructions of our company.

"Our Company" means our company (US), LLC, its predecessors, successors, subsidiaries, divisions and groups in the United States of America.

"Personal Information" means any information or set of information that identifies or could be used by or on behalf of our company to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

"Sensitive Personal Information" means Personal Information that reveals race, national origin, political opinions, religion or philosophical beliefs, or trade union membership, or that concerns criminal convictions, health, martial status, or sexual orientation, preference or activities. In addition, we will treat as Sensitive Personal Information any information received from a third party where that third party treats and identifies the information as sensitive.

4. Privacy Principles

The privacy principles in this Policy are based on the Safe Harbor Principles.

• Notice: Where our company collects Personal Information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses Personal Information about them, the types of non-agent third parties to which our company that information, and the choices and means, if any, we offer individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to our company, or as soon as practicable thereafter, and in any event before we use the information for a purpose other than that for which it was originally collected.

  Where our company receives Personal Information from its subsidiaries, affiliates or other entities in the EEA, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Information relates.

• Choice: We will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

  For Sensitive Personal Information, we will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

  Our company will provide individuals with reasonable mechanisms to exercise their choices.

• Data Integrity: Our company will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. We will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current.
• Transfers To Agents: Our company will obtain assurances from its Agents that they will safeguard Personal Information consistent with this Policy. Where we have knowledge that an Agent is using or disclosing Personal Information in a manner contrary to this Policy, we will take reasonable steps to prevent or stop such use or disclosure.
• Access And Correction: Upon request, our company will grant individuals reasonable access to Personal Information that it holds about them. In addition, we will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
• Security: Our company will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
• Enforcement: Our company will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. If we determine that an employee is in violation of this Policy, such individual will be subject to disciplinary action up to and including termination of employment.
• Dispute Resolution: Any questions or concerns regarding the use or disclosure of Personal Information should be directed to our Legal Department at the address given below. In addition, if you have a complaint concerning the use or disclosure of Personal Information or Sensitive Personal Information, please contact our Legal Department. Our Legal Department will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of Personal Information and Sensitive Personal Information in accordance with the principles contained in this Policy.

  For complaints that cannot be resolved by our Legal Department between our company and the complainant, we have agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.

5. Internet Privacy

Our company sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, healthcare professionals, business partners, and others. We recognize the importance of maintaining the privacy of information collected online and has created a specific Privacy Policy governing the treatment of Personal Information and Sensitive Personal Information collected in its data system and through web sites that it operates. With respect to Personal Information and Sensitive Personal Information that is transferred from the EEA to the U.S., that policy is subordinate to this Policy. However, the Internet Privacy Policy also reflects additional legal requirements and evolving standards with respect to computer and Internet privacy.

6. Contact Information

Questions or comments regarding this Policy should be submitted to our Legal Department at the following address:

Susanna J. Gray, Esq.
Assistant General Counsel
Legal Department
100 Enterprise Drive
Rockaway, New Jersey 07866
U.S.A.

7. Amendment

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Appropriate notice will be given concerning such amendments.

8. Effective Date

This Policy is effective February 1, 2010.