BBK Worldwide's Privacy Policy

Last modified April 5, 2012
At BBK Worldwide, LLC ("BBK," or "we," or "us," or "our"), we take personal privacy seriously.
We comply with applicable state, federal, and international requirements for the protection of personally identifiable information, including the federal health information privacy rule in the United States known as HIPAA (the Health Insurance Portability and Accountability Act), our certification under the United States' Safe Harbor Principles for complying 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, Canada's Personal Information and Electronic Documents Act (PIPEDA), and Australia's National Privacy Principles (NPPs) and Health Records Act. The following is our Privacy Policy ("Privacy Policy" or "Policy") in detail, which applies only to information that we collect through our Web site, www.bbkworldwide.com (the "Web site").

PERSONALLY IDENTIFIABLE INFORMATION
This Policy applies to personally identifiable information. "Personally identifiable information" is any information that could be used to contact or locate the person to whom it relates (such as name, address, telephone number, or any other identifying information), which may be combined with any health information about that person. Personally identifiable information does not include information, any single item of which, by itself, cannot be used to identify or contact you, such as demographic information (like age, professional current location, zip code, birth date, year of birth, or gender), or information about groups of people rather than individuals, which we sometimes use to track clinical study patient enrollment, or to show demographic trends or geographic groupings. Personally identifiable information also does not include user IP addresses, browser types, domain names, purchasing history and trends, and statistical data involving the use of the Web site.

USE OF PERSONALLY IDENTIFIABLE INFORMATION
Except as otherwise provided in this Policy, we will keep your personally identifiable information private and will not share it with third parties outside our controlled subsidiaries and affiliates unless such disclosure is necessary and permitted by applicable law to: (a) comply with applicable law, legal process (such as a court order, subpoena, or search warrant), or other legal requirements of any governmental authority; (b) protect our rights or property; (c) enforce any terms and conditions of use or agreements applicable to our Web site and that incorporate this Policy by reference, including any subscription agreements to which you may have agreed in connection with our Sponsor Resources or other services; (d) protect the interest of users of our Web site, other than you, or any other person or the general public; (e) detect fraud; or (f) operate or conduct maintenance and repair of our services or equipment, as authorized by law.

BBK is a marketing consulting firm for the clinical research and development segment of the pharmaceutical, biotechnology, and medical device industries, helping to accelerate time to market for new medicines and treatments.

In order for you to access certain services that we may offer via our Web site or otherwise, we may require you to provide us with personally identifiable information. In general, we use your personally identifiable and other information to deliver the services or carry out the transactions you have requested, to help us understand who uses the Web site, for internal operations such as to improve the Web site, to contact you for customer service and billing purposes, to facilitate the delivery of advertising, to contact you about products and services that may be of interest to you, to communicate with you generally, and to send certain mandatory service communications, such as subscription-related communications. You may choose not to provide us with any personally identifiable information. In such an event, you can still access and use much of our Web site. You, however, will not be able to access and use those portions of the Web site that require your personally identifiable information.

Whenever a person visits our corporate Web site, www.bbkworldwide.com, our Web server automatically recognizes the visitor's domain name. We collect, and may use for marketing and other similar purposes, the e-mail addresses and other personally identifiable and non-personally identifiable information of users, aggregate information on what pages visitors access, and any other information volunteered by visitors such as survey or registration information. For example, without requiring a user to "opt-in," we may send the user electronic newsletters, contact the user about products, services, information, and news that may be of interest to the user, and provide the user with targeted feedback. In addition, if a user identifies himself or herself to us by sending us an email with questions or comments, we may use the user's information (including personally identifiable information) to respond to the user's questions or comments, and we may file such questions or comments for future reference. We may also use the information collected to send important service announcements and updates regarding the Web site or, if applicable, about billing account status. In addition, we may use the information gathered on the Web site to perform statistical analysis of user behavior or to evaluate and improve the Web site. We may link some of this information to personally identifiable information for internal purposes only or to improve users' experience with the Web site.

As noted below, Submissions from users, including Submissions that contain personally identifiable information, are not subject to this Privacy Policy and may be used in any lawful manner, including any public manner.

All information collected may be used or shared by BBK as described in this Privacy Policy on a worldwide basis.

INFORMATION SUBMITTED TO PUBLIC AREAS OF THE WEB SITE
All comments, feedback, blog statements, suggestions, ideas, photographs, and other information and submissions disclosed, submitted, or offered by you in connection with your use of the public areas of the Web site, including without limitation any blog areas (collectively, "Submissions") are available to all users. Such Submissions are not protected or treated as confidential, can be used in any manner, and are not subject to this Policy. If you wish to keep any information private or proprietary, do not submit it to the public areas of the Web site, which include, but are not limited to, the Web site's blogs, discussion boards, messages, comment, and question and answer areas. WE HAVE NO RESPONSIBILITY OR LIABILITY IF A USER'S INFORMATION OR IDENTITY IS MISUSED OR STOLEN, OR IF A USER SUFFERS HARM AS A RESULT OF SUCH SUBMISSIONS.

INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE
We are committed to protecting the privacy of children. The Web site is not designed for or directed to children under the age of 13 and we do not collect personally identifiable information from any person we actually know is under the age of 13.

SALE OF BUSINESS
We may transfer, sell, or assign information concerning your use of this Web site – including, without limitation, personally identifiable information – to third parties, as a result of the sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation of BBK.

AFFILIATES
We may disclose personally identifiable and other information about Web site users to our Corporate Affiliates. For purposes of this Privacy Policy, "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by, or is under common control with BBK, whether by ownership or otherwise. Any information relating to Web site users that we provide to our Corporate Affiliates may be used by our Corporate Affiliates in any way that we may use such information under the terms of this Privacy Policy and will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

THIRD PARTIES GENERALLY
We may provide to third parties non-personally identifiable information about you, including where such information is combined with similar information of other users of the Web site. For example, we might inform third parties regarding the number of unique users who visit the Web site, the demographic breakdown of our registered users of the Web site, or the products and/or services purchased using the Web site and the vendors of such products and services. The third parties to which we may provide non-personally identifiable information may include potential or actual advertisers, providers of advertising products or services (including vendors and website tracking services), merchants, affiliates, and other actual or potential commercial partners, sponsors, licensees, researchers, and other similar parties.

THIRD PARTY SELLERS
In addition, through the Web site, you may be given the opportunity to purchase (or to obtain more information regarding) certain content, products, or services that are sold by parties other than us (collectively, "Merchants"). In other circumstances, through your use of the Web site, Merchants may request that you submit certain information to them in order to purchase their products or services or to obtain additional information from them. By submitting the requested information, you affirmatively consent to have that information shared with the Merchant. This information is used by the Merchant and may be subject to a different privacy policy. We are not responsible for the privacy practices of Merchants. We encourage you to be aware when the Web site links to Merchants' websites and to read the privacy policies or statements of each and every Merchant website. This Policy applies solely to information collected through the Web site.

OUTSIDE CONTRACTORS
We may employ independent contractors, vendors, and suppliers, such as a call center, mail house, or any other third party who may need to receive or handle personally identifiable information on our behalf (collectively, "Outside Contractors") to provide specific services and products related to the Web site, such as hosting and maintaining the Web site, providing credit card processing and fraud screening, providing shipping services, and developing applications for the Web site and e-mail services. In the course of providing products or services to us, these Outside Contractors may sometimes have limited access to information collected through the Web site, including your personally identifiable information. We require these Contractors to maintain their own equivalent Privacy Policy or enter into a written non-disclosure agreement and agree not to use personally identifiable information for any purpose other than the purpose for which we retained them. We also require such contractors to comply with all applicable state, federal, and international privacy requirements.

DATA SECURITY
Whenever we store or transmit personally identifiable information, we use a number of security procedures to prevent unauthorized access or disclosure. Our Web site has security measures in place intended to protect the loss, misuse, and alteration of the information under our control. We will take reasonable steps to safeguard personally identifiable information we collect from unauthorized access or disclosure and accidental loss, alteration, or destruction. Notwithstanding the above commitments to protect your personally identifiable information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.

LINKS TO OTHER WEBSITES
Our Web site may contain links to other websites not owned or operated by BBK (for example, if you "click" on a banner advertisement, you will likely be taken off the Web site). However, please be aware that we are not responsible for the privacy practices of such websites. We encourage you to be aware when the Web site links to other websites and to read the privacy policies or statements of each and every website. This Privacy Policy applies solely to information collected through use of the Web site.

HIPAA COMPLIANCE
The Health Insurance Portability and Accountability Act (HIPAA) is the United States federal law that controls the use and disclosure of personally identifiable health information by health insurers and healthcare providers, called "covered entities" under the statute. We are not a covered entity under the statute and HIPAA does not apply to the personally identifiable information that a person interested in participating in a study has voluntarily provided to a call center or Web site we set up for a clinical study. HIPAA does apply to any personally identifiable information transmitted by a study site if the site is a covered entity under HIPAA.

COMPLIANCE WITH INTERNATIONAL REQUIREMENTS
Our company 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. Our company has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view BBK's TCN e-Systems, LLC's certification, please visit www.export.gov/safeharbor.

BUSINESS TRANSITION
If we experience a business transition that affects the way personally identifiable information is treated in any material way, such changes will be included in an updated version of this Policy posted in the same locations as the previous version of the Policy. We encourage you to check the Web site periodically for any changes.

ACCEPTANCE OF PRIVACY POLICY
By using our Web site, you signify your assent to our Policy. If you do not agree with this Policy, you are not permitted to use our Web site. Your continued use of this Web site following posting of changes to these terms will mean you accept those changes.

ACCESSING OR CHANGING PERSONALLY IDENTIFIABLE INFORMATION
Anyone wishing to review or change his or her own personally identifiable information should contact the privacy officer at BBK Healthcare, Inc., 320 Needham Street, Newton, MA 02464, +1.617.630.4477, inquiry@bbkworldwide.com by mail, telephone, or e-mail.

OTHER INQUIRES, COMMENTS, OR COMPLAINTS
If you have a concern or complaint about our handling of your personally identifiable information, or if you believe our response to an inquiry has not been satisfactory, please contact our privacy officer at the address above. Our privacy officer will investigate and try to resolve in a timely manner any concern or complaint about our use or disclosure of your personally identifiable information in accordance with the principles contained in this Policy. For any concern or complaint that cannot be resolved in this way, we have agreed to cooperate with the American Arbitration Association to resolve any disputes relating to this Policy. The American Arbitration Association can be contacted at www.adr.org or 1.800.778.7879.

POLICY CHANGES
You should be aware that we may revise this Privacy Policy at any time, but we will not make changes that result in significant additional uses or disclosures of a user's personally identifiable information without allowing the user to "Opt In" to such changes. For clarification, we reserve the right to make changes to this Policy that generally do not result in significant additional uses or disclosures of a user's personally identifiable information without requiring the user to "Opt In" to such changes. We will post updated versions of this Policy on the Web site. We encourage you to check the Web site periodically for any changes. Continued use of the Web site following the posting of changes to this Policy constitutes acceptance of those changes.