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Tricida, Inc. Privacy Shield Privacy Policy

Overview

Tricida, Inc. (“Tricida,” “we,” “us,” or “our”) complies with the requirements of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce (the “Principles”).  Tricida has certified that it adheres to the Principles with respect to personal information (as described below) that is transferred from the European Union and its Member States, and the European Economic Area and Switzerland (“EU”) to the United States.  If there is any conflict between the terms in this Privacy Shield Policy and the Principles, the Principles shall govern.  Tricida is subject to investigatory and enforcement powers of the U.S. Federal Trade Commission.

This Privacy Shield Policy applies to personal information within the scope of Tricida Privacy Shield certification, which covers the personal data in the following categories:

  1. Personal data related to study participants, clinical research investigators and their staff as well as medical and healthcare professionals. The collection of personal information such as contact information, qualifications, debarment status and account information facilitates the proper conduct of research studies and the conduct of other study related services. Information collected may be transferred to business partners, Tricida affiliates and third-party service providers performing study related duties and may furthermore be transferred to regulatory authorities;
  2. Personal data related to prospective study participants, prospective investigators, and users of Tricida applications and websites who make enquiries regarding Tricida products or services and who may be asked to provide personal information in order to provide the requested information, products or services. Personal information provided may be used for the processing of requested transactions, improving the quality of our services, sending communications about our products and services, enabling our business partners and service providers to perform certain activities on our behalf and complying with our legal obligations, policies and procedures.
  3. Tricida may use the personal information it collects to comply with our legal obligations, policies and procedures and for internal administrative purposes.

For the purposes of this Privacy Shield Policy, “personal information” means any information relating to an identified or identifiable natural person.  In addition, certain personal information covered by Tricida Privacy Shield certification may be subject to more specific privacy policies of Tricida, which are also consistent with the requirements of the Principles, and in the case of any conflict between these policies and the Principles, the Principles will control.

For example:

Individual Notice and Choice

We collect and process personal information from certain individuals and for the purposes described in this Privacy Shield Policy.  Personal information covered by this Privacy Shield Policy is collected and processed only as permitted by the Principles.

Notice to individuals regarding the personal information collected from them and how that information is used may be provided through this Privacy Shield Policy, other Tricida website notices, or other direct forms of communication with appropriate parties, such as contracts or agreements.  Where necessary and appropriate, consent for personal information to be collected, used, and/or transferred may also be obtained through these same means of communication (including opt-in consent for sensitive personal information).

Disclosures & Accountability for Onward Transfers

Consistent with the Principles, Tricida may transfer personal information to third parties, including transfers from one country to another.  We will only disclose an individual’s non-public personal information to third parties under one or more of the following conditions:

Access

Individuals whose personal information is covered by this Privacy Shield Policy have the right to access the personal information that Tricida maintains about them as specified in the Principles. Individuals may contact us to correct, amend, limit usage of, or delete such personal information if it is inaccurate or has been processed in violation of the Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated).  Requests for access, correction, limitation, amendment or deletion should be sent to: privacy@tricida.com.

Security

Tricida takes appropriate measures to protect personal information in its possession to ensure a level of security appropriate to the risk of loss, misuse, unauthorized access, disclosure, alteration, and destruction.  These measures take into account the nature of the personal information and the risks involved in its processing, as well as best practices in the industry for security and data protection.

Data Integrity and Purpose Limitation

Tricida collects and processes personal information only to the extent that it is compatible with the purposes for which it was collected or subsequently authorized by the data subject.  Tricida does not retain personal information that does not serve the legal, regulatory, or business purposes for which it was collected or subsequently authorized.  Tricida takes reasonable steps to ensure that personal information is accurate, complete, current, and reliable for its intended use. In certain circumstances, individuals can request to limit our usage of personal data. To make such a request, please contact us at privacy@tricida.com

Enforcement

In compliance with the Principles, Tricida commits to resolve complaints about our collection or use of your personal information.  Individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact Tricida at: privacy@tricida.com. Tricida has a policy of responding to individuals within thirty (30) days of an inquiry or complaint.

If an individual has an unresolved complaint or concern that is not addressed satisfactorily, Tricida agrees to cooperate and comply with the EU data protection authorities (DPAs) and the Swiss Federal Data Protection Information Commissioner (FDPIC) regarding the unresolved complaints of data subjects who are located in the EU and Switzerland.  Such individuals may direct complaints about their personal information to their respective DPA.  For the contact information for your country’s DPA, please contact us at the address given below. Tricida commits to cooperate with DPAs and the FDPIC, and to comply with the advice given by such authorities with regard to non-human resources data transferred from the EU and Switzerland in the context of any relevant employment relationship.

You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances.  For further information, please see the Privacy Shield website. To learn more about the Privacy Shield Framework, and to view Tricida certification, please visit https://www.privacyshield.gov.

Modifications

Tricida may update this Policy at any time by publishing an updated version here.  We will not update this Privacy Shield Policy in contravention to the Principles so long as we remain certified to the Privacy Shield.

Privacy shield policy effective: January 23, 2019