AG Mednet, Inc. (“AGM”) a corporation headquartered in the United States (“US”) respects the privacy of the clients, employees, business partners, and individuals, among others, with whom it interacts. AGM treats personal information in accordance with both the laws and regulations of the countries from which the information is collected and in which it does business.
AGM complies with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework (the “Privacy Shield Framework(s)”) as set forth by the US Department of Commerce (“USDC”) in consultation with the European Commission (“EC”) and Swiss Administration (“SA”) regarding the regarding the collection, use, and retention of Personal Information transferred from EU and European Economic Area (“EEA”) member countries and Switzerland.
AGM also complies with the Privacy Shield Frameworks regarding the collection, use, and retention of Personal Information transferred from EU and European Economic Area (“EEA”) member countries and Switzerland to the US pertaining generally to clinical research site staff such as investigators, health care professionals, project managers and administrators and potential and active clinical research participants and patients (to the extent the transferred data sets are not key-coded as outlined under the Privacy Shield Supplemental Principle 14).
AGM has also designated both a Privacy Officer and a Security Officer, who are responsible for all data privacy policies, procedures, compliance and related issues.
AGM collects Personal Information to operate effectively and efficiently and in delivering its Services. Personal Information includes, among others:
Within AGM’s Clinical Trial System (CTS), AGM does not collect Personal Health Information (PHI) nor make decisions on when, where or how PHI is collected. AGM’s Clinical Trial System (CTS) does provide features to properly de-identify images (prior to leaving the sender’s workstation) and enforce de-identification workflows according to protocol requirements.
AGM uses Personal Information to establish and manage its relationship with its clients and to perform any related functions, including providing Services and related communications to you.
For example, AGM may use Personal Information to:
Certain Personal Information will be reported to government and regulatory authorities where required by law and for tax or other purposes. Personal Information may also be released to external parties as required or permitted by employment or other statutes and regulations, or by legal process, as well as to parties to whom individuals expressly authorize AGM to release their Personal Information. AGM will not sell any Personal Information to any third party other than in connection with the sale or transfer of all, or substantially all of AGM’s business or assets, or in connection with a merger, consolidation, or other reorganization.
AGM may be forced to disclose Personal Information when compelled by a lawful request made by a recognized public authority or where required to meet national security and or law enforcement requirements. AGM is subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”) and or the Food and Drug Administration (“FDA”).
Personal Information may also be made available to third parties providing relevant services under contract, such as auditors and compliance managers, background verification, legal and IT hosting and maintenance providers, among others). AGM will maintain appropriate security and privacy measures with such third parties including how they hold and maintain any Personal Information that is provided to them.
AGM is committed to ensuring that Personal Information is secure. In order to prevent unauthorized loss, alternation, destruction, access, use or disclosure of Personal Information, AGM maintains adequate physical, administrative and technical safeguards, including the following:
Individuals whose Personal Information has been collected by AGM shall have the right to access that data for review, modification or deletion.
Access to review, modify and or delete your Personal Information or otherwise manage the use and disclosure of your Personal Information (“opt-out”) may be initiated by contacting AGM in writing as follows:
AG Mednet, Inc.
The Pilot House, Lewis Wharf
Boston, MA 02110
Even after it has processed your request for a change or deletion, AGM may retain certain residual information in the backup and/or archival copies of AGM’s database for audit purposes, for its customers’ protection, and to comply with laws or regulations. For example, AGM will retain certain audit trail information for at least as long as is required for the subject electronic records, and it will be available for agency review and copying.
Within AGM’s Clinical Trial System (CTS), AGM does not monitor the content of images on the network for Personal Information. If notified by the customer that data retained by AGM contains Personal information, AGM will work with the customer to remove such data from its database and to alter the de-identification workflow as required by the customer to eliminate future occurrences.
In instances in which AGM collects Personal Information directly from individuals, it will provide information about the type, use and purpose of the of Personal Information it collects, the identity of third parties to which AGM will disclose the Personal Information, and the choices and means that it offers individuals for limiting use and disclosure of such Personal Information, upon request.
In instances in which AGM receives Personal Information as a service provider for its clients, such clients are responsible for providing appropriate notice to (and obtaining any necessary consent from) the individuals whose Personal Information is transferred to the US.
AG Mednet, Inc.
The Pilot House, Lewis Wharf
Boston, MA 02110
AGM has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the US and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Under certain limited conditions it is possible to seek recourse through last resort binding arbitration.