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Privacy Policy – Sigma-Aldrich Global Advisors Panel

Last updated 1/25/10

 

US-EU Safe Harbor Privacy Policy

Welcome to the Sigma-Aldrich Global Advisors Panel Privacy Policy. References to “you”, “participant” and “panelist” refer to any individual online user or customer who agrees to participate in the Sigma-Aldrich Global Advisors Panel (the “Panel”). The Panel may consist of a variety of studies to which different groups of participants may be invited to participate. As a panelist, you may be asked to provide Sigma-Aldrich Global Advisors (the "Company", “us” or “we”) with Personal Information as part of our research, testing, and internal corporate goals. It is the policy of the Company to respect Personal Information, including Sensitive Personal Information (if any) that is collected or maintained by or on behalf of the Company. In furtherance of this commitment, the Company has certified to the US-EU “Safe Harbor” agreement regarding Personal Information collected in the United States, European Economic Area (EEA), and Switzerland, and transferred to the United States. The Company adheres to the Safe Harbor privacy principles as agreed to by the U.S. Department of Commerce and the European Commission and as outlined in this US-EU Safe Harbor Privacy Policy (the "Privacy Policy").

Scope
This Privacy Policy sets forth the principles under which the Company manages, collects, uses and stores Personal Information collected from individuals who have agreed to participate in the Panel. The Panel may consist of online surveys and/or interactive discussions. Such Personal Information will be collected from residents of the United States, EEA, Switzerland and other countries who have affirmatively agreed to participate in the Panel. Sensitive Personal Information will not be collected from Global Advisors panelists.

Definitions
"Personal Information" means any information that identifies or describes an identified or identifiable living natural person. "Personal Information" may include, for example, name, user id, password, signature, employee identification number, social security number, address, telephone number, e-mail address, company name, insurance policy number, job title, financial information, account numbers or any other information that is capable of being associated with a particular identifiable individual. Personal Information does not include aggregate data that have been divorced from identifiable characteristics.

"Sensitive Personal Information" is a subset of Personal Information, and includes information pertaining to an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information related to an individual’s health or sex life, as well as biometric identifiers, such as finger and voiceprints, and information as to commission or alleged commission of a criminal offense or any related proceedings.

We have developed the following Safe Harbor practices and policies to safeguard your information.

 

Safe Harbor Principles

  • Notice
  • Collection of Your Personal Information
  • Use of Your Personal Information
  • Choice
  • Onward Transfer
  • How long the Company Keeps and Uses Personal Information
  • Disposal of Personal Information
  • Security
  • Collection and Use of Children's Personal Information
  • Access
  • Data Integrity
  • Use of Cookies
  • Enforcement
  • Dispute Resolution
  • Limitation on Scope of Principles
  • How to Contact Us

Safe Harbor Principles

Notice: The Company notifies Panel participants about the identity of the entity who collects and controls the collected data, the purpose(s) for which it collects, processes and maintains the data, and any further information as may be required by the circumstances under which the data is collected including the types of Personal Information the Company collects from and about Panel participants, the data recipients or categories of data recipients, the proposed transfer of such data to third countries (if applicable), the types of third parties to which it discloses such data (if any) and the right of access to the data. Notice is provided in clear and conspicuous language at the time of collection, or as soon as practicable thereafter, and before the Company uses or discloses the information for a purpose other than that for which it was originally collected.

Process of Collecting Personal Information: The Company will request that you provide Personal Information when you register to become a Panel participant. After you register as a participant, you will be instructed on how to access your Panel(s). As a Panel participant, you may be asked to provide your opinions, expertise and recommendations on a variety of topics affecting the Company’s products and services. The Company is always seeking better ways to serve you and has implemented the Global Advisors Panel in order to understand your opinions of our services and products, your requirements as to new products, services and improvements to better serve your business needs. We will use the Panel to share information regarding studies that we have run via the Panel or to share news from our Company. We will collect Personal Information from Panel participants primarily through online surveys or discussion forums, but we may also use telephone calls, fax, or other communication efforts.

Use of Your Personal Information: The Company collects and uses all Personal Information from Panel participants solely for its internal business purposes, including research and testing, input on new and existing products and services, information, suggestions, opinions and ideas which will help improve the operation of our web sites and add value to our products and services. After collecting information from Panel participants, we may use the information to verify the identity of a Panel participant, categorize group demographics comprising a Panel, analyze how a Panel collectively responds to questions, and use this information further to improve our websites, eliminate the need for repetition of required information for each website session; conduct research and analysis aimed at improving our products, services and technologies.

Choice: You have been invited, at your option, to participate in a Panel, and have indicated through your affirmative consent that you have agreed to participate and have further read and consent to the terms of this Privacy Policy. In the event the Company chooses to use your Personal Information for a new purpose incompatible with the purposes for which your Personal Information was originally collected or subsequently authorized, or if the Company transfers the Personal information to the control of a third party that has not been previously identified as acting as an agent of the Company, Panel participants will be given notice of such use and, where feasible and appropriate, an opportunity to decline to have their data so used or transferred.

Collection, Storage and Onward Transfer of Personal Information: All Personal Information and other data collected by the Company from Panel participants during the course of a Panel (and, if applicable, during the registration process) will be stored on and processed by the Company’s agent, Vision Critical, a market research data collection and processing company located in Canada or such other third party successor that the Company hires to provide the services described in this paragraph (Vision Critical and any successor company being an “agent”). Vision Critical will store the Personal Information and other data on a secured server and will use SSL (Secure Sockets Layer) protocol to transmit Personal Information and other data from Vision Critical’s server to the Company’s own secured server by a password protected and encrypted file or through a file transfer protocol (FTP) site. Vision Critical or a successor agent may also act as a data processor to compile Personal Information and other data provided during a Panel in accordance with the Company’s instructions. Other than collecting, storing, and processing the Personal Information as the Company’s agent and transferring the Personal Information (compiled if appropriate) back to the Company’s server, Vision Critical will take no other action with respect to your Personal Information and exercises no ownership rights or control over your Personal Information. Vision Critical has provided assurances to the Company that it will meet the above security requirements, that it provides at least the same level of privacy protection as is required by this Privacy Policy, and that it will not use the Personal Information in any manner outside the scope of this paragraph. The Company will ensure that any successor agent exercises the same duty of care. If the Company has knowledge that its agent is using or sharing Personal Information in a way that is contrary to these principles, the Company will take reasonable and appropriate steps to prevent or stop such processing.

How the Company Keeps and Uses Personal Information: The Company reserves the right to store Personal Information obtained from Panel participants during the registration process and Panel activities from the time of registration until the Panel data has been thoroughly processed and used in the manner described in this Privacy Policy. If you continue to be a registered Panel participant, your Personal Information provided during registration may be retained until you end your participation. Under no circumstances will the Company disclose any Personal Information it obtains during registration or a Panel to any third party other than Vision Critical or its successor agent, nor will it use the information for any purpose outside of the scope of this Privacy Policy. There is no definitive end date for use of the Personal Information collected as such end date is dependent on the type of data collected and the purpose and extent of the Panel.

If required by commercial laws and regulations, the Company will continue to store Personal Information on its servers or on or the agent’s server for the period specified by the law.

Disposal of Personal Information:

  1. Disposal Procedures: All Personal Information collected during registration will be transferred and stored into a secure electronic database (or a designated box for hardcopies) for the specific period noted above or as otherwise required by internal regulations, the US-EU Safe Harbor Agreement, or any other laws regarding data safeguard guidelines. Your Personal Information will be completely disposed of at the end of this period. We will not use any Personal Information retained in the database for any purposes other than as outlined in this Privacy Policy. If necessary to the processing of Panel specific information, copies of your Personal Information provided during registration will also be stored temporarily on the agent’s server and processed as part of the Panel data.
  2. Disposal Method: we use technical means to completely remove any personal information in electronic data file format and make them unrecoverable permanently.

Security: The Company and its agent will meet the security standards described above to protect Personal Information stored on their services and transmitted between them from loss, misuse, alteration, destruction, or unauthorized access or disclosure.

Collection and Use of Children's Personal Information: The Company does not knowingly collect any personal information from children under the age of 14 that require their parent's consent regarding personal information collection, nor does it intentionally design any of its sites to attract users under the age of 14. They are also restricted from customer registration.

Access: Panel participants have reasonable access to their Personal Information, and may request corrections, deletions, or additions, as appropriate, except where the burden or expense of providing such access would be disproportionate to the risks to the individual data subject's privacy.

Data Integrity: The Company limits the collection, usage, and retention of Personal Information to that which is germane to the relevant purposes described in this Privacy Policy and takes steps to ensure that any Personal Information is accurate, complete, current and reliable for the intended use.

Use of Cookies

The Company sites use "cookies" to enable you to register as a Panel participant and to actively participate in a Panel and to help personalize your online experience. A cookie is a small text file that is placed on your hard disk by a Web page server. Cookies contain information that can later be read by a Web server in the domain that issued the cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to sign in as a panelist or use other interactive features of the Company sites and services that depend on cookies. In addition, certain advertising preferences that are dependent on cookies may not be able to be utilized.

If you choose to accept cookies, you also have the ability to later delete cookies that you have accepted. If you choose to delete cookies, any settings and preferences controlled by those cookies will be deleted and may need to be recreated.

Enforcement: The Company has put in place mechanisms to verify its ongoing compliance to these privacy principles. Any Company employee found to have violated the privacy principles in this Privacy Policy will be subject to appropriate corrective actions.

Dispute Resolution: The Company is committed to resolving any disputes that may arise by internal investigation and resolution of the issue. Should the Company's efforts to resolve an issue be unsuccessful, the Company will facilitate the resolution of such disputes including through the submission of disputes to an independent party. Within the EEA and Switzerland, any questions, concerns or comments about this Privacy Policy may be directed to the Data Privacy Officer at the relevant office of the Company or to the Corporate Legal Department. The Company agrees to cooperate with EEA and Switzerland Data Privacy Authorities regarding any dispute concerning Personal Information.

Limitation on Scope of Principles

Adherence by the Company to the privacy principles set forth in this Privacy Policy may be limited to the extent necessary to meet the Company's regulatory, legal, governmental, or national security obligations.

How to Contact Us

Please contact us with any questions concerning this Privacy Policy or any of the Company's privacy practices at:

 

Sigma-Aldrich Corporation

General Counsel

3050 Spruce Street

St. Louis, MO 63178

privacy@sial.com

Changes to this Privacy Policy

This Privacy Policy may be amended consistent with the requirements of the US-EU Safe Harbor Agreement. When we do update this Privacy Policy, we will also revise the "Last Updated" date at the top of this document. Any material changes to this Privacy Policy will also be posted on the Sigma-Aldrich Advisors web page (http://www.sigma-aldrichadvisors.com/).

 

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