Makro respects individual privacy and values the confidence of its
customers, employees, clinical trial participants, business partners and
others. Not only does Makro 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
(the “Policy”) sets forth the privacy principles that Makro follows
with respect to transfers of personal information from the European Union (EU)
to the United States.
The United States Department of Commerce and the European Commission have
agreed on a set of data protection principles and frequently asked questions
(the “Safe Harbor Principles”) to enable U.S. companies to satisfy the
requirement under European Union law that adequate protection be given to
personal information transferred from the EU to the United States. Consistent
with its commitment to protect personal privacy, Makro adheres to the
Safe Harbor Principles.
information received by Makro 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
Makro to perform tasks on behalf of and under the instructions of
"Makro" means Makro, 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 Makro 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,
Makro 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 Makro 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 Makro discloses that information, and the choices and means, if
any, Makro 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
Makro, or as soon as practicable thereafter, and in any event before
Makro uses the information for a purpose other than that for which it
was originally collected.
Where Makro 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.
Makro 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, Makro 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. Makro will provide
individuals with reasonable mechanisms to exercise their choices.
Makro will use personal information only in ways that are compatible
with the purposes for which it was collected or subsequently authorized by the
individual. Makro will take reasonable steps to ensure that personal
information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS:
Makro will obtain assurances from its agents that they will safeguard
personal information consistently with this Policy. Where Makro has
knowledge that an agent is using or disclosing personal information in a manner
contrary to this Policy, Makro will take reasonable steps to prevent
or stop the use or disclosure.
ACCESS AND CORRECTION:
Upon request, Makro will grant individuals reasonable access to
personal information that it holds about them. In addition, Makro
will take reasonable steps to permit individuals to correct, amend, or delete
information that is demonstrated to be inaccurate or incomplete.
Makro will take reasonable precautions to protect personal
information in its possession from loss, misuse and unauthorized access,
disclosure, alteration and destruction.
Makro will conduct compliance audits of its relevant privacy
practices to verify adherence to this Policy. Any employee that Makro
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 Makro Privacy Office at the
address given below. Makro 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 Makro and the complainant, Makro
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
Makro Privacy Office by mail or e-mail as follows:
Makro Privacy Office
One Washington Park, Suite 1502
Newark, NJ 07102