Privacy Policy

1.  Introduction

  • The privacy of our website visitors is very important to us, and we are committed to safeguarding it. This policy explains what we will do with your personal information.

  • Consenting to our use of cookies in accordance with the terms of this policy when you first visit our website permits us to use cookies every time you visit our website.

2.  Collecting personal Information

 

Generally, you can visit the Website without revealing who you are and without disclosing any of your personal information. However, there may be times when we require personal information about you or when you wish to disclose such personal information to us. Such personal information is obtained when submitted by you and is subject to the provisions set out in this Privacy Statement. The following types of personal information may be collected, stored, and used:

  • Information that you provide by filling in forms on the website, such as your personal details (e.g. your name) or contact details (e.g., telephone number, email address, etc).

  • Information, such as your name and email address, that you enter in order to set up subscriptions to our emails and/or newsletters.

  • If you contact us, in writing, by email or other electronic means, we may keep a record of that correspondence.

  • Details of your visits to the website and information as you navigate through the website together with details of the resources that you access. This information includes, but is not limited to: usage details, IP addresses, location data and other communication data which will be used in accordance with our Cookie Statement.

  • Information contained in any communications that you send to us by email or through our website, including its communication content and metadata;

 

Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy

 

3.  Using your personal information

Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website. We may use your personal information for the following:

  • administering our website and business;

  • personalizing our website for you;

  • sending you email notifications that you have specifically requested;

  • dealing with inquiries and complaints made by or about you relating to our website;

  • keeping our website secure and prevent fraud;

  • verifying compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service); and

  • other uses.

 

4.  Disclosing personal information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy.

 

We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

  • to the extent that we are required to do so by law;

  • in connection with any ongoing or prospective legal proceedings;

  • in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);

  • to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and

  • to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this policy, we will not provide your personal information to third parties.

 

5.  International data transfers

  • Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.

  • Information that we collect may be transferred to a country that is not regarded as ensuring an adequate level of protection for Personal Information under EU law.

  • Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

  • You expressly agree to the transfers of personal information described in this Section.

6.  Retaining personal information

  • This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal information.

  • Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes and in accordance with our record retention policy, as updated from time to time, and as long as we have a relationship with you.

  • Notwithstanding the other provisions of this Section, we will retain documents (including electronic documents) containing personal data:

    • to the extent that we are required to do so by law;

    • if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

    • in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

 

7.  Security of your personal information

  • We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.

  • We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

  • You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

8.  Amendments

We may update this policy from time to time by publishing a new version on our website. You should check this page periodically  to ensure you understand any changes to this policy.

 

9.  Cookies

Our website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

 

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

 

10.  Contact Us


Transformative Pharmaceutical Solutions LLC is based in the US and is the controller responsible for personal information that it collects and processes. If you have any questions or concerns regarding the way in which your personal information is used, please contact us via mail at 1777 Sentry Parkway West, Building 17, Suite 100, Blue Bell, PA 19422 marking your letter for the attention of the Data Protection Officer. Our Data Protection Officer can be contacted at DPO@tpsglobal.com.

DATA PRIVACY NOTICE FOR E.U. EMPLOYEES AND CONTRACTORS

This Notice describes Transformative Pharmaceutical Solutions’ practices with respect to the collection, use, storage, and disclosure (“processing”) of Personal Information of employees and contractors covered by the European Union’s General Data Protection Regulation. This Notice applies to Transformative Pharmaceutical Solutions, with global headquarters at 1777 Sentry Parkway West, Suite 100, Building 17, Blue Bell, PA  19422, as well as to its affiliated legal entities and branches (collectively “TPS”, “us” or “our”) solely with respect to employees or contractors of TPS’ operations in the European Union. All such persons (referred to below as “you” or “your”) should carefully read the provisions of this Privacy Notice.

“Personal Information,” as used in this Notice, means any information that can be used to identify you, whether directly or indirectly, including by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.

 

Questions?

You can contact TPS’ data privacy department with any questions about this notice, our data collection practices, or your rights. You can reach us, at: 1777 Sentry Parkway West, Suite 100, Building 17, Blue Bell, PA  19422 Ph:  267-468-7074, or by:  Privacy@TPSGlobal.com (the “Contact Person”).

 

This general notice may be supplemented by additional notices at the point of any data collection. We may modify the manner in which we collect and process personal data from time to time and will advise you of any such changes.  If you have specific questions about any of the data processing activities described in this or any other notice, please contact the Contact Persons.

 

The Information We Process About You

We process the information we collect from you directly or indirectly, either during our communications with you, when you apply for work (either as an employee or a contractor, when you sign up for benefits, or when you make use of TPS equipment and systems, facilities, programs, resources, and services provided by third-party vendors utilized by TPS.  Any such third-party vendors will collect and process your personal data in a manner consistent with this Notice and in accordance with applicable law.  This includes information about your employment history (including your history with TPS), your job performance, compensation and benefits, and your dependents and emergency contacts.

 

In some cases, certain information will be required in order for TPS or third-party vendors used by TPS to determine your eligibility for work, compensation, promotion, benefits, or to otherwise provide you with the services you are requesting. We will mark that information as “Required” or “Mandatory.” Failure to provide required or mandatory information may result in your being denied work, promotion, benefits, or access to other services that TPS, or third-party vendors used by TPS, offers.

 

We use automated decision-making processes to process your data in certain contexts. For example, we may automatically evaluate information about your compensation and benefits to withhold taxes or determine your eligibility for employment or other benefits or other programs. You can find out more about the logic we use in our automated decision-making processes by contacting the Contact Persons.

 

In addition, we collect the following kinds of information about you from third parties:

 

  • Information about your employment history and education: We collect information about your employment history and education during the interview and/or application process or when taking an employment action – such as considering you for a promotion or a new position at TPS. We collect this information from your previous employers (or references provided by you) and the educational institutions you attended.

 

  • Information about your professional certifications or licenses: We collect information about any professional certifications or licenses you might have from third parties to provide or verify those certifications or licenses.

 

  • Information about your health: We, or third-party vendors, may collect information about your health from your health care provider or another third party you direct us to.

 

  • Information we collect from other employees and/or local, regional, or national governmental authorities (the “Authorities”). Other employees or Authorities may provide us with information about you, whether in the process of reporting an incident involving you, alerting us to an emergency situation involving you, or as part of the employment process. This information can include your name, information about your behavior or activities, and other information about the situation being reported to us.

 

  • Background checks:  We are required by our clients to conduct background checks on all prospective employees and contractors.  These background checks are conducted by a third-party.  These background checks include criminal background checks, motor vehicle and transportation checks, and checks on personal information.  In addition, we are required to provide mandatory drug testing to all prospective employees and contractors.  We will collect all such data and such data will be shared upon request in a generalized format and with any client of TPS for whom the prospective employee or contractor will provide services.

 

  • Immigration information: Governments and consulates may provide us with government identification, immigration information, or other information in order to facilitate travel related to services you provide to TPS. The type of information provided may vary by country depending on applicable reporting requirements. For example, the Czech government may report information regarding criminal convictions and debts.

 

Purposes and Legal Basis for Processing Your Data

We may also be required to process your Personal Information to comply with laws applicable in the European Union or its member states.

 

You can obtain additional information about the processing we do to comply with applicable laws by contacting the Contact Persons.

 

In the case of Sensitive Personal Information (which includes information about your health, race, ethnicity, national origin, criminal convictions, religious or philosophical beliefs, sexual orientation, biometric data and trade union membership), we process information either (i) because we have your consent to do so or (ii) because we are required to process the information to comply with applicable laws or by our clients. For example, we are required to process sensitive data to comply with background checks that our clients require us to perform on anyone who will be rendering services, directly or indirectly, to such clients.

 

You can obtain more information about these laws by contacting the Contact Persons. When we process your Sensitive Personal Information on the basis of your consent, you may withdraw that consent at any time by contacting the Contact Persons. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.

 

Finally, we process your Personal Information for additional purposes that are compatible with those already described, including for the purposes of complying with our clients’ recordkeeping requirements. Where possible, we do not use identifiable information for these purposes, or we take steps, including making use of pseudonymous data, to limit the amount of Personal Information we use in our research or archives.

 

Recipients of Your Personal Information

Your Personal Information will be received and processed by TPS employees and personnel, including third parties who provide services to TPS.  We share your Personal Information with our service providers or clients only when they have agreed to process your Personal Information only to provide services to us, or as part of internal compliance processes, and have agreed to protect your Personal Information from unauthorized use, access, or disclosure. You may contact us to learn more about the categories of service providers to whom your data is disclosed.

 

We may also disclose your contact information at TPS in directories available to employees, and members of management of TPS. You may request that your information be removed from this directory.

 

We also disclose your information to government authorities as required by laws that regulate immigration, tax, national security, and criminal activity.

Transfers to Third Countries

TPS is a limited liability company headquartered in the United States. We transfer your data to the United States and to the countries where we operate, including, but not limited to, various countries which are members of the European Union and the United Kingdom. Data that is collected about you may be shared with our global headquarters in the United States and other global locations during the period of your employment.

 

TPS has executed Standard Contractual Clauses, as approved by the European Commission. These clauses permit TPS to transfer data from the EU to third countries, including the United States. If you would like to receive a copy of TPS’ Standard Contractual Clauses, you can contact the Contact Persons.

Data Retention

We will retain your data throughout your period of employment and for a period of 5 years thereafter. We may be required by law to retain your information for a longer period.  If you have any questions, you may contact the Contact Persons.

 

Your Rights

You have the right to the following information regarding TPS’ processing of your Personal Information:

  • the purposes of the processing,

  • the categories of Personal Information concerned,

  • the recipients or categories of recipients to whom the Personal Information have been or will be disclosed,

  • where possible, the envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period.

 

This Data Privacy Notice is intended to provide this information. Any questions about these details may be directed to the Contact Persons.

 

You also have the following additional rights with respect to your Personal Information:

  • The right to request access to the Personal Information that TPS and/or third-party vendors utilized by TPS have about you, as well as the right to request rectification of any data that is inaccurate or incomplete.

  • The right to request a copy of your Personal Information in electronic format so that you can transmit the data to third parties, or to request that TPS or such third-party vendors directly transfer your Personal Information to one or more third parties.

  • The right to object to the processing of your Personal Information for marketing and other purposes.

  • The right to erasure of your Personal Information when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your Personal Information to certain limited purposes where erasure is not possible.

  • The right to lodge a complaint with the appropriate supervisory authority where you believe that your rights have been violated.

DATA PRIVACY NOTICE FOR AUSTRALIAN EMPLOYEES AND CONTRACTORS

This Notice describes Transformative Pharmaceutical Solutions’ practices with respect to the collection, use, storage, and disclosure (“processing”) of Personal Information of employees and contractors covered by the Australia’s Privacy Act 1988 and Privacy Principles. This Notice applies to Transformative Pharmaceutical Solutions, with global headquarters at 1777 Sentry Parkway West, Suite 100, Building 17, Blue Bell, PA  19422, as well as to its affiliated legal entities and branches (collectively “TPS”, “us” or “our”) solely with respect to employees or contractors of TPS’ operations in Australia. All such persons (referred to below as “you” or “your”) should carefully read the provisions of this Privacy Notice.

 

“Personal Information,” as used in this Notice, means any information that can be used to identify you, whether directly or indirectly, including by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.

 

Questions?

You can contact TPS’ data privacy department with any questions about this notice, our data collection practices, or your rights. You can reach us, at: 1777 Sentry Parkway West, Suite 100, Building 17, Blue Bell, PA  19422 Ph:  267-468-7074, or by:  Privacy@TPSGlobal.com (the “Contact Person”).

 

This general notice may be supplemented by additional notices at the point of any data collection. We may modify the manner in which we collect and process personal data from time to time and will advise you of any such changes.  If you have specific questions about any of the data processing activities described in this or any other notice, please contact the Contact Persons.

 

The Information We Process About You

We process the information we collect from you directly or indirectly, either during our communications with you, when you apply for work (either as an employee or a contractor, when you sign up for benefits, or when you make use of TPS equipment and systems, facilities, programs, resources, and services provided by third-party vendors utilized by TPS.  Any such third-party vendors will collect and process your personal data in a manner consistent with this Notice and in accordance with applicable law.  This includes information about your employment history (including your history with TPS), your job performance, compensation and benefits, and your dependents and emergency contacts.

 

In some cases, certain information will be required in order for TPS or third-party vendors used by TPS to determine your eligibility for work, compensation, promotion, benefits, or to otherwise provide you with the services you are requesting. We will mark that information as “Required” or “Mandatory.” Failure to provide required or mandatory information may result in your being denied work, promotion, benefits, or access to other services that TPS, or third-party vendors used by TPS, offers.

 

We use automated decision-making processes to process your data in certain contexts. For example, we may automatically evaluate information about your compensation and benefits to withhold taxes or determine your eligibility for employment or other benefits or other programs. You can find out more about the logic we use in our automated decision-making processes by contacting the Contact Persons.

 

In addition, we collect the following kinds of information about you from third parties:

 

  • Information about your employment history and education: We collect information about your employment history and education during the interview and/or application process or when taking an employment action – such as considering you for a promotion or a new position at TPS. We collect this information from your previous employers (or references provided by you) and the educational institutions you attended.

 

  • Information about your professional certifications or licenses: We collect information about any professional certifications or licenses you might have from third parties to provide or verify those certifications or licenses.

 

  • Information about your health: We, or third-party vendors, may collect information about your health from your health care provider or another third party you direct us to.

 

  • Information we collect from other employees and/or local, regional, or national governmental authorities (the “Authorities”). Other employees or Authorities may provide us with information about you, whether in the process of reporting an incident involving you, alerting us to an emergency situation involving you, or as part of the employment process. This information can include your name, information about your behavior or activities, and other information about the situation being reported to us.

 

  • Background checks:  We are required by our clients to conduct background checks on all prospective employees and contractors.  These background checks are conducted by a third-party.  These background checks include criminal background checks, motor vehicle and transportation checks, and checks on personal information.  In addition, we are required to provide mandatory drug testing to all prospective employees and contractors.  We will collect all such data and such data will be shared upon request in a generalized format and with any client of TPS for whom the prospective employee or contractor will provide services.

 

  • Immigration information: Governments and consulates may provide us with government identification, immigration information, or other information in order to facilitate travel related to services you provide to TPS. The type of information provided may vary by country depending on applicable reporting requirements.

 

Purposes and Legal Basis for Processing Your Data

We may also be required to process your Personal Information to comply with laws applicable in the European Union or its member states.

 

You can obtain additional information about the processing we do to comply with applicable laws by contacting the Contact Persons.

 

In the case of Sensitive Personal Information (which includes information about your health, race, ethnicity, national origin, criminal convictions, religious or philosophical beliefs, sexual orientation, biometric data and trade union membership), we process information (i) because we have your consent to do so, and (ii) because we may be required to process the information to comply with applicable laws or by our clients. For example, we are required to process sensitive data to comply with background checks that our clients require us to perform on anyone who will be rendering services, directly or indirectly, to such clients.

 

You can obtain more information about these laws by contacting the Contact Persons. When we process your Sensitive Personal Information on the basis of your consent, you may withdraw that consent at any time by contacting the Contact Persons. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.

 

Finally, we process your Personal Information for additional purposes that are compatible with those already described, including for the purposes of complying with our clients’ recordkeeping requirements. Where possible, we do not use identifiable information for these purposes, or we take steps, including making use of pseudonymous data, to limit the amount of Personal Information we use in our research or archives.

Recipients of Your Personal Information

 

Your Personal Information will be received and processed by TPS employees and personnel, including third parties who provide services to TPS.  We share your Personal Information with our service providers or clients only when they have agreed to process your Personal Information only to provide services to us, or as part of internal compliance processes, and have agreed to protect your Personal Information from unauthorized use, access, or disclosure. You may contact us to learn more about the categories of service providers to whom your data is disclosed.

 

We may also disclose your contact information at TPS in directories available to employees, and members of management of TPS. You may request that your information be removed from this directory.

 

We also disclose your information to government authorities as required by laws that regulate immigration, tax, national security, and criminal activity.

Transfers to Third Countries

TPS is a limited liability company headquartered in the United States. We transfer your data to the United States and to the countries where we operate, including, but not limited to, the United Kingdom. Data that is collected about you may be shared with our global headquarters in the United States and other global locations during the period of your employment.

 

Data Retention

We will retain your data throughout your period of employment and for a period of 5 years thereafter. We may be required by law to retain your information for a longer period.  If you have any questions, you may contact the Contact Persons.

 

Your Rights

You have the right to the following information regarding TPS’ processing of your Personal Information:

  • the purposes of the processing,

  • the categories of Personal Information concerned,

  • the recipients or categories of recipients to whom the Personal Information have been or will be disclosed,

  • where possible, the envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period.

 

This Data Privacy Notice is intended to provide this information. Any questions about these details may be directed to the Contact Persons.

 

You also have the following additional rights with respect to your Personal Information:

 

  • The right to request access to the Personal Information that TPS and/or third-party vendors utilized by TPS have about you, as well as the right to request rectification of any data that is inaccurate or incomplete.

  • The right to request a copy of your Personal Information in electronic format so that you can transmit the data to third parties, or to request that TPS or such third-party vendors directly transfer your Personal Information to one or more third parties.

  • The right to object to the processing of your Personal Information for marketing and other purposes.

  • The right to erasure of your Personal Information when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your Personal Information to certain limited purposes where erasure is not possible.

  • The right to lodge a complaint with the appropriate supervisory authority where you believe that your rights have been violated.

California Consumer Privacy Act (CCPA)