Privacy Policy


Introduction

Alere Inc. respects the privacy of its employees, its customers, and visitors to its website, and is committed to protecting the privacy of the Personal Information (defined below) that you share with us.  This Privacy Policy outlines the type of personal information that is collected by Alere Inc. when you contact us, visit our web site or in the employment context, and how we use and protect it. This Policy also tells you what to do if you do not want your Personal Information collected and how you can change information you have already provided to us.

Your consent:  By using our website, you consent to the collection, use and disclosure of information as described in this Policy.

Scope

This Policy applies to Alere Inc., and all of its wholly-owned subsidiaries and affiliates.  References to “Alere” in this policy refer to Alere Inc., and all of its wholly-owned subsidiaries and affiliates.  “Personal Information” means any information or set of information that identifies or can reasonably be used to identify an individual (the “Identifiable Person”). Personal Information does not include information that is encoded or anonymized, or publicly available information that has not been combined with nonpublic, personal information.  “Sensitive Personal Information” is data that pertains to medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation or any other data that is identified as “sensitive” by the Identifiable Person.

Purposes of Collection of Personal Information

Alere’s collection and use of Personal Information in the employment context is essential in connection with the conduct of Alere’s human resources and business functions. Examples of the purposes for which Alere collects and uses Personal Information include, without limitation, recruitment, payroll, and personnel management, such as compensation, promotion, evaluation, benefit administration and succession planning, and designing and implementing employment-related education and training programs, and maintaining facility and employee security, health, and safety.  Unless required by applicable law, Alere does not request or record Sensitive Personal Information.

To the extent practical and appropriate, Alere collects Personal Information directly from the Identifiable Person. In those cases where Alere collects Personal Information from other persons, it takes measures to respect the privacy preferences of the Identifiable Person. Examples of when Alere may seek information from others include, without limitation, evaluating employees, recruiting, benefit administration and succession planning.

Alere also collects Personal Information from contacts made through its website.  When Personal Information is supplied at an Alere website, we will use it for the express purpose for which it was collected, or for other purposes disclosed at the time when the Personal Information is supplied.  See “Information Collected on our Websites” below for additional information.

Alere also collects personal information, including health information, about EU individuals who use Alere products, for medical device reporting, warranty and product support purposes.

U.S.-European Union and Swiss Safe Harbor Programs

Alere complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland.  Alere has certified that is adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view Alere’s certification, please visit http://export.gov/safeharbor/index.asp

Notice

At the time that Alere collects Personal Information from you for any of the purposes identified above, we will inform you of the purpose for which the Personal Information is being collected and used, and how to contact Alere with any questions or complaints, or to update your Personal Information.  Alere will not disclose Personal Information to third parties except in accordance with this Policy and as disclosed at the time of the collection of the Information.

Choice

Alere 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 other than that for which the Personal Information was originally collected or subsequently authorized by you.

Alere will not disclose Sensitive Personal Information to a third party or use it for any purpose other than that for which it was originally collected or subsequently authorized by you, except as required by law, court order, or subpoena.

Security

Alere will take reasonable precautions to keep your Personal Information secure. All personally identifiable information is subject to restricted access to prevent unauthorized access, modification or misuse.

Data Integrity

Alere 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, Alere will take reasonable steps to ensure that Personal Information is relevant for its intended use, accurate, complete and current.

Access

Alere will provide you with reasonable access to your Personal Information collected or recorded by Alere, and will undertake reasonable steps to effect any correction or amendment of Personal Information that you demonstrate to be incorrect or incomplete.

Transfer to Third Parties

Before Alere transfers Personal Information to a third party that is acting as an agent, it will ascertain that the third party safeguards Personal Information consistent with this policy, has itself made a Safe Harbor certification, or is subject to the EU Data Protection Directive. Where Alere has knowledge that an agent is using or disclosing Personal Information contrary to this policy, Alere will take reasonable steps to prevent or stop the use or disclosure.

Enforcement

Alere will conduct periodic internal audits to our ongoing adherence to this Policy, and will promptly seek to remedy any instances of noncompliance brought to its attention.

Dispute Resolution

We encourage individuals covered by this Policy to raise any concerns that they have about the way that we protect and process their Personal Information by contacting privacy.info@alere.com or Ethics Compliance Officer, Alere Inc., 51 Sawyer Road, Suite 200, Waltham, MA 02453, and we will do our best to resolve them.  Alere will investigate your concerns promptly, and will respond to your correspondence within thirty (30) days after we receive it.  Alere will provide you with a clear explanation of any decisions made with respect to your request.

Employees who have concerns regarding the processing of their Personal Information are encouraged to notify Paul Hempel, Sr. V.P. Ethics/Compliance and Special Counsel at 51 Sawyer Road, Suite 200, Waltham, MA 02453. Complaints will be resolved in accordance with Alere’s existing formal complaints procedures.

For complaints that cannot be resolved between you and Alere,

(a) If you are not a resident of the European Union, any dispute arising between an Identifiable Person and Alere with respect to this Privacy Policy, including the breach, enforcement, interpretation or validity thereof, shall be resolved by binding arbitration conducted in Boston, Massachusetts by a single arbitrator.  The arbitration shall be administered by JAMS pursuant to its Streamlined Arbitration Rules and Procedures.  Judgment on the arbitration award may be entered in any court having jurisdiction.  This clause shall not preclude parties from seeking provisional remedies in aid of arbitration from a court of appropriate jurisdiction.

(b) If you are a resident of the European Union and have provided Personal Information in connection with an employment relationship with Alere, Alere has agreed to participate in the dispute resolution program provided by the European Data Protection Authorities Panel pursuant to the Safe Harbor principles.  Any Identifiable Person who is resident in the EU should address his or her concerns to his or her local data protection authority.

Information Collected on Our Websites

When you supply Personal Information at an Alere website, we will use it for the express purpose for which it was collected (e.g., to enter you in a sweepstake or to send you a sample). It may also be used by us to send you information and/or offers about our goods and/or services which we believe may be of interest to you, or to invite you to participate in market research. At any time, however, you may opt out of such future contact by writing us at privacy.info@alere.com or Privacy Officer, Alere Inc., 51 Sawyer Road, Suite 200, Waltham, MA 02453. 

At times we may retain third parties to process or analyze data we collect on our web sites, including Personal Information. In addition, if you order a product or service from us, we may share Personal Information with suppliers and other third parties to allow delivery of such product or service. These suppliers and other third parties are not authorized by us to use your Personal Information in any other way.

Alere may use “cookies” to collect other information during an individual’s visit to our web sites, such as the particular site areas visited and the services utilized through our web site. We collect this information to better tailor our site and our products to your interests and needs. Cookies may also be used to help speed up your future activities at our site. For example, a site can recognize that you have provided Personal Information to use and refrain from requesting the same information a second time. Most browsers are initially set to accept a cookie. Cookies may be disabled by the individual visitor, although refusal of cookies at the site may result in an inability to visit certain areas of the site or to receive personalized information when visiting the site.

In addition we are constantly trying to improve how we promote our web site. To help us do this, we may measure the effectiveness of our web presence by determining when you accessed the web site, and what you clicked on within our site. Site measurement statistics may be used to personalize your web site experience, as well as to evaluate – anonymously and in the aggregate – statistics about usage of the web site. Information about your computer, such as your IP address (a number assigned to your computer whenever you surf the Internet), the type of Internet browser you are using and the type of operating system you are using may also be collected and linked to your Personal Information. This is to ensure that our web site presents the best web experience for visitors, and that they are effective information resources.

Some of the pages an individual visits may also collect information through the use of pixel tags (also called clear gifs) that may be shared with third parties which directly support Alere’s promotional activities and web site development. For example, web site usage information about visitors to our web sites may be shared with our third party advertising agency in order to better target Internet banner advertisements on Alere Inc. web sites. The information collected through the use of these pixel tags is not, however, personally identifiable, although it could be linked to an individual’s Personal Information.

Finally, we may supplement the Personal Information that an individual website user provided us with other information we hold or that we receive from third parties. We do this for marketing purposes in order to provide more targeted products and service to meet site visitors’ needs.

Limitation on Scope of Principles

Please note that we will release your Personal Information if required to do so by law, or by search warrant, subpoena, or court order.

Changes to this Policy

This Policy may be amended from time to time, consistent with the requirements of the U.S.-EU Safe Harbor Framework and/or the U.S.-Swiss Safe Harbor Framework. When we do amend it, we will also revise the “last updated” date at the bottom of this Policy.

Version:  December 2012
Last Updated: March 2015