Willowglade Technologies Corporation Safe Harbor Policy
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Willowglade Technologies Company (the “Company”, “we”, “us”, or “our”) a Delaware Corporation providing a Personalized Patient Experience Platform and associated apps. We host the mobile application entitled “My Breast Cancer Journey”, “Cancer Journey Supporter” and its derivatives that are from time to time customized to meet the branding and other requirements of our Clients in Europe (collectively the “Apps”).
Protecting consumer information is important to us and the Company adheres to the Safe Harbor Agreement concerning the transfer of personal data from the European Union and Switzerland (together collectively the “EU”) to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the “Principles”) with respect to all such data. In the event of a conflict between the policies outlined herein and the Principles, the Principles shall govern. The Company has established this Safe Harbor Policy (the “Policy”) to outline our general policy and practices for implementing the Principles. The Policy covers the types of information we gather, how it is used, notice and choice provisions and dispute resolution provisions. The Policy applies to all personal information received by the Company, regardless of format.
For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s Website at http://export.gov/safeharbor.
Information that is (i) transferred from the EU to the United States; (ii) is recorded in any format; (iii) is about or pertains to a specific individual and (iv) can be linked to that individual shall be referred to as “Personal Information” or “Information”.
Information that is related to medical or health conditions, race, ethnicity, sexual orientation or practices, political opinions, religious or philosophical beliefs, trade union membership or information that concerns an individual’s health shall be referred to as “Sensitive Personal Information”.
Collection and Use of Information
The Company receives Personal Information that is collected by and/or provided by authorized members of our Apps (the “Member”).
THE COMPANY DOES NOT USE OR TRANSFER INFORMATION OTHER THAN IN FURTHERANCE OF THE PURPOSE FOR WHICH THE INFORMATION WAS COLLECTED; NAMELY, IN FURTHERANCE OF PROVIDING IMPROVED COMMUNICATION, COLLABORATION, EDUCATION OF PATIENTS WITH THEIR HEALTHCARE PROVIDERS AND FURTHERING THE RESEARCH ASSOCIATED WITH THE PATIENTS’ DIAGNOSIS.
The Company will allow Members the opportunity to choose whether Personal Information is to be disclosed to a third party or to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized. For Sensitive Personal Information, the Company will give Members the opportunity to affirmatively consent to the disclosure of such information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the Member. Company shall treat Sensitive Personal Information received from the Member at least as carefully as Company would treat its own employees’ similar information.
Prior to disclosing any Personal Information to a third party other than the Member, Company shall notify the Member of the choice to opt out of such disclosure. Company shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.
Company shall take any reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Company has in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction.
Company shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the Member.
Company shall allow the Member to access the Information, and, the Member shall have access to the Information. We shall allow the Member to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risk to the privacy of the Member.
Company uses a self-assessment approach to assure compliance with this Policy and periodically verifies that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and accessible and in conformity with the Principles. We encourage interested parties to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Information in accordance with the Principles.
If a complaint or dispute can not be resolved through our internal process, we agree to dispute resolution using JAMS ADR as a third party dispute resolution provider.
The Company does not collect human resource data.
Questions, comments or complaints regarding the Company’s Policy or data collection and processing practices may be mailed or emailed to:
Willowglade Technologies Corporation
29822 Avenida de las Banderas, Suite A
Rancho Santa Margarita, CA, 92688.