Privacy Policy

1. Introduction

As a globally integrated company, Cerius Hub’s business processes increasingly go beyond the borders of one country. This globalization demands not only the availability of communication and information systems across the Cerius Hub group of companies, but also the world-wide processing, sharing and use of multiple types of information including information about an individual whose identity is apparent (either directly and indirectly), or can be reasonably be ascertained from the information available or likely to be available (Personal Information).

This Policy letter sets forth the general principles which underlie Cerius Hub’s specific practices for collecting, using, disclosing, storing, retaining, disposing, accessing, transferring or otherwise processing Personal Information.

2. Applicability

This Policy applies to all Cerius Hub personnel, operating units, and any wholly owned subsidiaries worldwide and (as transferred and agreed) with suppliers/business partners who must act consistently with the principles contained in the policy. Country and industry-specific laws and regulations shall take precedence over this policy, to the extent applicable. The application of these principles is more particularly described in the applicable Cerius Hub Corporate Instructions (and any accompanying implementation Guidelines) relating to processing Personal Information. Please read this policy along with the company guidelines for use and processing of Personal Information to understand how Cerius Hub plans to achieve the set principles.

3. Privacy Policy Statement

Cerius Hub remains committed to protecting the privacy and confidentiality of Personal Information of its Employees (including prospects and contractors), Clients, Client Customers, Business Partners and other identifiable individuals that it may receive, use, access, process, transfer or store as part of its business. Uniform practices for collecting, using, disclosing, storing, retaining, disposing, accessing, transferring or otherwise processing such information assists Cerius Hub to process Personal Information fairly and appropriately.

Cerius Hub may collect personal information from various people as part of the services it may render to them, or in the course of its business. Based on the information being collected and nature of services or requirement, Cerius Hub will apply suitable mechanisms to ensure that Cerius Hub has a lawful basis for receiving, accessing, using, processing, transferring, storing and/or disposing such personal information.

SMS Communication Consent
By providing my phone number to Cerius Hub Corporation, I agree and acknowledge that Cerius Hub Corporation may send text messages to my wireless phone number for any purpose. Message and data rates may apply. Message frequency will vary, and I may opt out by replying “STOP.” For more information on how your data will be handled, please see our Privacy Policy below.

Privacy Policy:
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

4. General Privacy Principles

These general principles apply to the processing of Personal Information world-wide by Cerius Hub.

A. Accountability:
Cerius Hub understands its accountability and responsibility for any Personal Information that it may receive, use, process, store as part of its business. Accordingly, it will:

I. have appropriate corporate instructions, guidelines and other measures to be able to demonstrate that Personal Information is used/ stored / processed / retained / disposed / transferred in compliance with applicable law and other applicable guidelines;
II. designate an individual or individuals who are accountable for the organization’s compliance with the Privacy principles; and
III. ensure the availability of required policies, procedures and contacts for management of personal information; these being reviewed at a minimum annually or as and when there is a change warranted.

B. Consent, Fairness and Purpose:
Cerius Hub will only collect adequate, relevant and necessary Personal Information, and will process such Personal Information fairly and lawfully for the purposes for which the Personal Information was collected.

When collecting Personal information, the purposes, legal basis, and where required by applicable law, the consent of the individual, will be specified and / or obtained upon or before its initial collection and / or disclosure as well as before any previously collected Personal Information is Processed for a new or different purpose.

Individuals can withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Upon receipt, Cerius Hub will inform individuals of the implications of withdrawal.

C. Accuracy:
Cerius Hub will keep Personal Information as accurate, complete and up-to-date as is necessary for the purpose for which it is processed; and provide appropriate channels for the same.

D. Disclosure and Data Sharing:
Cerius Hub will make Personal Information available inside or outside Cerius Hub under appropriate circumstances for business purposes only or as authorized by law. This may require Cerius Hub to transfer personal information to countries other than Cerius Hub operation’s country of business (including transfer to other entities or third parties).

Cerius Hub will implement privacy principles for the use / processing/ transfer / storing, and disposal of personal information as may be prescribed under applicable laws.

E. Cross-Border Data Flows:
When conducting business, working on Company projects, or implementing newprocesses or systems, an operation may require the transfer of personal information to other entities or third parties that are located outside of the Cerius Hub operation’s country of business. While permissible data transfer mechanisms are defined by applicable law or regulation, examples include:

i. a data transfer agreement with the party who will access or obtain the personal
information; or
ii. notice to and/or approval from a country’s local data protection authority; or
iii. notice to and/or consent from the individual whose data is to be transferred.

F. Security:
Cerius Hub will implement reasonable technical and organizational measures to safeguard Personal Information and instruct third parties processing Personal Information on behalf of Cerius Hub to process and manage it in a manner which is consistent with Cerius Hub standards (for Cerius Hub owned information) or Cerius Hub Client standards (for Client information), as may be applicable.

G. Access:
Upon request, Cerius Hub will, within a reasonable time, manner, and in a readily intelligible form provide individuals appropriate access to Personal Information retained by Cerius Hub. Cerius Hub has the right to deny the request; however, the reasons of denial will be provided. Cerius Hub will erase, rectify, complete, or amend the data pursuant to a justified request.

H. Retention and Disposal:
Cerius Hub will retain Personal information in a form that permits identification for no longer than as necessary for the fulfillment of the stated purpose and should be disposed thereafter.

I. Transparency:
Cerius Hub will be transparent and make readily available to individuals specific information related to management of Personal Information.

J. Custodianship:
Cerius Hub will follow appropriate policies and practices agreed with its clients for the safe handling of Personal Information that it processes on behalf of its clients.

5. Enforcement and Redressal

Cerius Hub will provide appropriate robust mechanisms for assuring compliance with the principles, and address grievance and / or provide recourse for individuals who are affected by non-compliance with the principles.

6. Contacting Cerius Hub’s Data Privacy Office

If you have any questions, requests or grievances pertaining to this Privacy Policy or other privacy matters you may contact Cerius Hub’s Data Privacy Office or James Scheuermann, Vice President of Legal and Compliance at dpo@ceriushub.com or at Cerius Hub, 851 Duportail Rd., FL 2, Chesterbrook, PA 19087.