WHRDG respects the privacy of its employees, its customers and visitors to its website and is committed to protect the Personal Information (defined below) that you share with us. WHRDG makes reasonable efforts to protect your Personal Information.  WHRDG’s privacy program and data security activities are governed by this policy and other policies and procedures.  With respect to Personal Information about individuals (“data subjects”) located in European Union (EU) countries, Iceland, Lichtenstein and Norway (the European Economic Area) WHRDG also adheres to a self-regulatory program that complies with the safe harbor privacy principles set forth in the July 2000 agreement between the EU and the United States Department of Commerce (Safe Harbor Program).  For more information about the Safe Harbor Program, please go to http://www.export.gov/safeharbor.  As used in this policy, "Personal Information" is information relating to an identified or identifiable natural person that identifies that person. 

WHRDG collects, processes, and stores Personal Information for the following purposes:

• Determining, evaluating, and implementing employment-related actions and obligations.

• Designing, evaluating, and administering compensation, benefits, and other human resources programs.

• Designing, evaluating, and implementing employment-related education and training programs.

• Monitoring and evaluating employee conduct and performance.

• Maintaining plant and employee security, and health and safety.

• Collecting and storing customer information.

• Maintaining business records relating to past, present, and potential customers, suppliers, contractors, joint venture partners, other business associates, and employees.

• Conducting auditing, accounting, financial, and economic analyses.

• Facilitating business communications, negotiations, transactions, conferences, and compliance with contractual and legal obligations.

• Providing good and services, including clinical studies, to our customers.

• Monitoring the website, which includes processing orders and engaging in transactions and communications

SCOPE
This policy applies to The Willis Human Resource Development Group and all of its subsidiaries and affiliates around the world, and applies to all goods and services provided by WHRDG.  References to “WHRDG” in this policy refer to Willis Human Resource Development Group its subsidiaries and affiliates around the world.

EU SAFE HARBOR PROGRAM
WHRDG abides by the Safe Harbor Program’s data privacy principles with respect to transfers of Personal Information between the United States and member states of the European Economic Area.  The privacy principles in this policy are based on the Safe Harbor Program’s Principles.

Notice
WHRDG may obtain Personal Information from data subjects through the purposes identified above. At the time WHRDG collects Personal Information from you, it will inform you of the purposes for which it collects and uses such information and how to contact WHRDG with any inquiries or complaints. WHRDG will not disclose Personal Information to third parties.

Choice
WHRDG will offer you the opportunity to choose whether your Personal Information is to be (a) disclosed to a third party or (b) used for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized by you.

Security
WHRDG will take reasonable precautions to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Data Integrity
WHRDG will not process your Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you. To the extent necessary for those purposes, WHRDG will take reasonable steps to ensure that Personal Information is relevant for its intended use, accurate, complete and current.

Access
WHRDG will provide you with reasonable access to your Personal Information that it holds and will undertake reasonable steps to permit you to correct, amend or delete that information demonstrated to be inaccurate or incomplete.

Transfer to Third Parties
When WHRDG transfers information to a third party that is acting as an agent, before doing so it will ascertain that the third party either safeguards Personal Information consistent with this policy, is subject to the EU Directive 95/46/EC (the EU Data Protection Directive, Safe Harbor certification in the U.S by the third party, or by being subject to another European Commission adequacy finding). Alternatively, WHRDG may enter into a written agreement with such third party requiring that the third party provide at least the same level of privacy protection as required by the relevant principles of this policy. Where WHRDG has knowledge that an agent is using or disclosing Personal Information contrary to this policy, WHRDG will take reasonable steps to prevent or stop the use or disclosure.

Enforcement
WHRDG will conduct compliance audits of its relevant privacy practices to verify adherence to this policy. Any employee that WHRDG determines is in violation of this policy will be subject to disciplinary action.

INFORMATION COLLECTED AND SUBMITTED ON THE WEBSITE

When you browse our Web site, you do so anonymously, unless you have previously indicated that you wish WHRDG to remember your login and password. We do not automatically collect Personal Information, including your email address. We do log your IP address to give us an idea of which part of our Web site you visit and how long you spend there. But we do not link your IP address to any Personal Information unless you have logged in to our Web site. We do use a standard technology called “cookie” to collect information about how you use the site. Please go to “Web Browser Cookies” below for more information.

WHRDG collects Personal Information when you register with WHRDG for an account, when you ask to be included in an email or other mailing list, when you submit your personal information to WHRDG for any other reason. When Personal Information is collected, we will inform you at the point of collection.

Server log files
Our server log files are stored in a secure location, and can only be accessed by specified employees of WHRDG. This information is kept indefinitely for historical purposes. This information is used to analyze trends, administer the site, track user movement in the aggregate, and gather broad demographic information for aggregate use.

Database storage
We make use of multiple databases to record and retrieve information sent to us through web forms (such as contact information, products and services requested, and any billing/payment information, etc.). This information is kept indefinitely for historical purposes. This information is used for billing purposes and to fill customer's orders. If we have trouble processing an order, the information is used to contact the user.

Web browser cookies
We make use of a web browser cookie for the sole purpose of giving the visitors of our Web site the option to login quickly, without the hassle of putting in the username and password of their account. These cookies are created by the visitors browser, and are generally saved somewhere on the visitor's hard drive. Visitors have the ability to disable this feature at any time, either by unselecting "Automatically login from this computer" in their account information, or by disabling the use of cookies on their web browser. The cookie that we create will last for exactly one year from the time of creation, at which time a new cookie will be created upon the next login.

Information Submitted Through the Website
In some areas of our Web site you are offered the opportunity to submit Personal Information.

Medical investigators who have an interest in working with WHRDG in clinical studies may submit information to our Investigator Database. Information gathered via the Investigator Database is shared with our clients who are interested in conducting clinical studies in the therapeutic areas described by the registering investigator.

Patients participating in any clinical study managed by WHRDG, or those acting on their behalf, who submit unsolicited information to a Web site, including Personal Information, may expect that we will share that information with our client who is responsible for the study, the medical investigator supervising the patient’s participation in the study, the institutional review board supervising the study and others who may have an interest in that particular patient’s experience in the clinical study. If a patient sends an unsolicited email to our Web site regarding a clinical study, we reserve the right to use or disclose the information contained in the email to third parties without seeking any additional consent from the patient.

Our Web site also contains forms for completion and submission, such as on our Contact Us page and Career Opportunities page. Information submitted via these forms will be used for the purposes described on the page containing the form. You may expect that information submitted will be shared with the appropriate WHRDG employees and agents necessary to take action on the information or request submitted. For example, resumes and information related to those seeking employment will be shared with the staff of the WHRDG Human Resources Department and other WHRDG employees involved in the hiring process.

Information Security
WHRDG takes every precaution to protect data subjects’ information, whether collected on-line or otherwise. When data subjects submit sensitive information via the Web site, their information is protected both online and off-line.

When our order form asks data subjects to enter sensitive information (such as credit card number), that information is encrypted and is protected with the best encryption software in the industry: SSL. While on a secure page, such as our order form, the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when data subjects are just 'surfing.’

While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect data subject-information off-line. All of our data subjects' information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to Personal Information. Finally, the servers that store Personal Information are in a secure environment, in a locked facility.

The Web site is not intended or designed to attract children. We do not collect information or data on our Web site from children under the age of 13 nor do we desire to receive any information or data from children who visit our Web site.

Updating Personal Information on the Website
If a data subject's Personal Information changes (such as zip code, phone, email or postal address), we provide a way to correct and update data subjects' Personal Information. This can usually be done by selecting "Modify my account information" after logging in.

SHARING OF PERSONAL INFORMATION

Legal disclaimer
WHRDG will not transfer your Personal Information to third parties without your consent, except under limited conditions. Though we make every effort to preserve data subject privacy, we may need to disclose Personal Information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our Web site. WHRDG is a global company, your Personal Information may be shared with other WHRDG offices or subsidiaries around the world. All such entities are governed by this Privacy Policy or are bound by the appropriate confidentiality and data transfer agreements. If you choose to provide us with your Personal Information, we will only transfer that information with your permission.

Third party intermediaries
We use an outside shipping company to ship orders, and a credit card processing company to bill data subjects for goods and services. These companies do not retain, share, store or use Personal Information for any secondary purposes.

Business transitions
In the event WHRDG goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, data subjects' Personal Information will, in most instances, be part of the assets transferred. Data subjects will be notified via a notice on our Web site prior to a change of ownership or control of their Personal Information. If as a result of the business transition, the data subjects' Personal Information will be used in a manner different from that stated at the time of collection they will be given choice consistent with our notification of changes section.

COMMUNICATION

Automatic emails
Our server will automatically send you an email at certain events during a web form submission. These events include but are not limited to first time account creation, forgotten password retrieval, order confirmation, etc. These emails are strictly used to keep the data subject well informed.

Customer service
We communicate with data subjects on a regular basis to provide requested services and in regards to issues relating to their account we reply via email or phone.

LINKS TO OTHER SITES
This Web site contains links to other sites. Please be aware that we, WHRDG, are not responsible for the privacy practices of such other sites. We encourage our data subjects to be aware when they leave our site and to read the privacy statements of each and every Web site that collects Personal Information. This policy applies solely to information collected by this Web site.

NOTIFICATION OF POLICY CHANGE
Please note that this policy may be amended, from time to time.  If we decide to change our privacy policy, we will post those changes to this policy, and other places we deem appropriate so our data subjects are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected.  Any such changes will comply with the EU Safe Harbor Program.

WEB SITE TERMS AND CONDITIONS
By using the Web site, you agree to the terms and conditions set forth herein. Furthermore, you acknowledge and agree that the documents and articles contained on the Web site are the property of WHRDG and may contain copyrighted materials, proprietary trademarks and trade names of WHRDG. No material from any Web site owned, operated, licensed or controlled by WHRDG may be copied, reproduced, republished, uploaded, posted, transmitted or distributed in any way.

Commercial enterprises seeking to do business with WHRDG should not submit unsolicited confidential or proprietary information to WHRDG’s Web site. WHRDG reserves the right to use or disclose unsolicited information for any purpose.

WHRDG makes no representations about the content and suitability of the information in the Web site for any purpose. The articles, information and works provided in the Web site are provided "AS IS", WITHOUT ANY WARRANTY OF ANY KIND, EITHER EXPRESSED OR IMPLIED, WHETHER CONTRACTUAL OR STATUTORY, INCLUDING, BUT NOT LIMITED TO, ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT OR OTHERWISE. WHRDG assumes no liability for the use or interpretation of information contained herein. Decisions based on such information are the responsibility of the data subject. WHRDG is not liable for any direct, indirect, special, incidental or consequential damages arising out of the use, or the inability to use, the material on the Web site. If you do not agree to these terms and conditions, do not use the Web site.

CONTACT INFORMATION
If data subjects have any questions or suggestions regarding this policy, please contact us at:  CustomerRelations@WHRDG.com