The privacy principles in this Policy are based on the Safe Harbor Principles.
NOTICE: Where Merck 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 Merck discloses that information, and the choices and means, if any, Merck offers 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 Merck, or as soon as practicable thereafter, and in any event before Merck uses or discloses the information for a purpose other than that for which it was originally collected.
Where Merck receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose 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: Merck 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, Merck 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.
Merck will provide individuals with reasonable mechanisms to exercise their choices.
DATA INTEGRITY: Merck will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Merck will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS: Merck will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). Where Merck has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Merck will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION: Upon request, Merck will grant individuals reasonable access to personal information that it holds about them. In addition, Merck will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
SECURITY: Merck will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
ENFORCEMENT: Merck will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Merck determines is in violation of this policy 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 the Merck Privacy Office at the address given below. Merck will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Merck and the complainant, Merck has 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.
Merck respects individual privacy and values the confidence of its customers, employees, clinical trial participants, consumers, business partners and others. Not only does Merck strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that Merck follows with respect to personal information transferred from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.
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