Privacy Policy

BIOMEDICAL SYSTEMS CORPORATION
SAFE HARBOR PRIVACY POLICY

Biomedical Systems respects individual privacy and values the confidence of its customers, employees, clinical trial participants, consumers, business partners and others. Not only does Biomedical Systems 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 Biomedical Systems 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.

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 and Switzerland also has recognized the U.S. Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47).

Biomedical Systems Corporation 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.  Biomedical Systems Corporation 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 Biomedical Systems Corporation’s certification, please visit http://www.export.gov/safeharbor/.

This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received by Biomedical Systems in the United States from the European Economic Area, in any format including electronic, paper or verbal.

DEFINITIONS
For purposes of this Policy, the following definitions shall apply: "Agent" means any third party that uses personal information provided by Biomedical Systems to perform tasks on behalf of and under the instructions of Biomedical Systems. "Biomedical Systems" means Biomedical Systems Corporation, its predecessors, successors, subsidiaries, divisions and groups. "Personal information" means any information or set of information that identifies or could be used by or on behalf of Biomedical Systems 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, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, Biomedical Systems will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES
The privacy principles in this Policy are based on the Safe Harbor Principles.
1. NOTICE: Where Biomedical Systems 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 Biomedical Systems discloses that information, and the choices and means, if any, Biomedical Systems 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 Biomedical Systems, or as soon as practicable thereafter, and in any event before Biomedical Systems uses the information for a purpose other than that for which it was originally collected. Where Biomedical Systems 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.
2. CHOICE: Biomedical Systems 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, Biomedical Systems 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. Biomedical Systems will provide individuals with reasonable mechanisms to exercise their choices.
3. ONWARD TRANSFERS TO AGENTS: Biomedical Systems 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 Hungary and Switzerland). Where Biomedical Systems has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Biomedical Systems will take reasonable steps to prevent or stop the use or disclosure.
4. SECURITY: Biomedical Systems will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
5. DATA INTEGRITY: Biomedical Systems will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Biomedical Systems will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
6. ACCESS: Upon request, Biomedical Systems will grant individuals reasonable access to personal information that it holds about them. In addition, Biomedical Systems will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
7. ENFORCEMENT: Biomedical Systems will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Biomedical Systems 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 Biomedical Systems Privacy Office at the address given below. Biomedical Systems 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 Biomedical Systems and the complainant, Biomedical Systems 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.

CONTACT INFORMATION
Questions or comments regarding this Policy should be submitted to the Biomedical Systems Privacy Office by mail or e-mail as follows:
Biomedical Systems Privacy Office
Biomedical Systems Corp.
77 Progress Parkway.
Maryland Heights, MO 63043
This e-mail address is being protected from spambots. You need JavaScript enabled to view it.

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY
This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Appropriate public notice will be given concerning such amendments.

EFFECTIVE DATE: December 7, 2011