DDi respects individual privacy and values the confidence of its customers, employees, clinical trial participants, business partners and others. Not only does DDi strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles that DDi follows with respect to transfers of personal information from the European Union (EU) to the United States.

In accordance with our commitment to protect personal privacy, DDi adheres to the principles of the Safe Harbor Framework as developed by the U.S. Department of Commerce in consultation with the European Commission. The seven principles and fifteen Frequently Asked Questions (FAQs) referred to in this policy constitute Safe Harbor privacy framework. These principles and FAQs may be found at: http://www.export.gov/safeharbor

This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received by DDi in the United States from the EU, in any format including electronic, paper or verbal.

For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that uses personal information provided to DDi to perform tasks on behalf of and under the instructions of DDi.

"DDi" means DDi, its successors, subsidiaries, divisions and groups in the United States.

"Personal information" means any information or set of information that identifies or could be used by or on behalf of DDi to identify an individual. Personal information does not include information that is encoded or anonymized or publicly available information that has not been combined with non-public personal information.

"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, DDi will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

The privacy principles in this Policy are based on the Safe Harbor Principles.

Where DDi collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses personal information about them, the types of non-agent third parties to which DDi discloses that information, and the choices and means, if any, DDi offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to DDi, or as soon as practicable thereafter, and in any event before DDi uses the information for a purpose other than that for which it was originally collected.

Where DDi receives personal information from its subsidiaries, affiliates or other entities in the EU, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

DDi will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, DDi will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. DDi will provide individuals with reasonable mechanisms to exercise their choices.

DDi will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. DDi will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

DDi will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Where DDi has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, DDi will take reasonable steps to prevent or stop the use or disclosure.

Upon request, DDi will grant individuals reasonable access to personal information that it holds about them. In addition, DDi will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

DDi will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.DDi keep client's information for three years from the date of last service rendered.

DDi will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that DDi determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

Any questions or concerns regarding the use or disclosure of personal information should be directed to the DDi Privacy Office at the address given below. DDi will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between DDi and the complainant, DDi has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.

Questions or comments regarding this Policy should be submitted to the DDi Privacy Office by mail or e-mail as follows:

DDi Privacy Office
One Washington Park, Suite 1502
Newark, NJ 07102