Safe Harbor Policy

Biosense Webster, Inc., a member of The Johnson & Johnson Family of Companies, is strongly committed to protecting the privacy of those who entrust us with their personal information. Our employees, and all those who do business with us, trust and expect that we will protect their personal information in accordance with the promises we make. In furtherance of our commitment, Biosense Webster, Inc. has certified to the Safe Harbor Agreement between the United States and the European Union, with respect to personal data processed as part of our human resources, clinical research, customer marketing, and health care professional activities. Accordingly, Biosense Webster, Inc. adheres to the Safe Harbor privacy principles and Frequently Asked Questions, as agreed to by the U.S. Department of Commerce and the European Commission.

The following privacy principles apply to the collection, use and disclosure of personal data by Biosense Webster, Inc. in conducting clinical research, human resources, customer marketing , and health care professional activities.

Notice

Biosense Webster, Inc. will inform individuals about the purposes for which we collect and use personal data about them, how to contact us, the types of non-agent third parties with whom we may share personal data, and any ways that individuals may limit the use and sharing of such data. This notice will be provided when individuals are first asked to provide personal data or as soon thereafter as is practicable.

Choice

Biosense Webster, Inc. will offer an individual the opportunity to choose (opt out) whether personal data are (a) shared with a non-agent third party or (b) used for a purpose other than that for which the data were originally collected or subsequently authorized by the individual.

For sensitive personal data, Biosense Webster, Inc. will give an individual an affirmative or explicit (opt in) choice if the information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected or subsequently authorized by the individual.

Access

Biosense Webster, Inc. will provide individuals with reasonable access to personal data about them, and they may request the correction, deletion or amendment of personal data that they demonstrate to be incorrect or incomplete.

Transfers to Agents

Biosense Webster, Inc. will only transfer personal data to an agent where the agent has provided assurances that the agent provides at least the same level of privacy protection as is required by these privacy principles. Where we have knowledge that an agent is using or sharing personal data in a way that is contrary to these principles, Biosense Webster, Inc. will take reasonable steps to prevent or stop such processing.

Onward Transfer

Biosense Webster, Inc. will only transfer personal data to a non-agent third party where consistent with the notice provided to the individuals who are the subject of the data and any consent that those individuals have given.

Information Integrity

Biosense Webster, Inc. will only use and share personal data about individuals in a way that is consistent with the purposes for which the data were collected or subsequently authorized by those individuals. To the extent necessary for those purposes, Biosense Webster, Inc. will take reasonable steps to ensure that the data are accurate, complete, and current.

Information Security

Biosense Webster, Inc. will take reasonable precautions to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Enforcement

Biosense Webster, Inc. has put in place mechanisms to verify our ongoing adherence to these privacy principles. We encourage individuals covered by this Policy to raise any concerns that they have about the way that we process their personal data by contacting us via email at privacyofficer@its.jnj.com and we will do our best to resolve them. We have also agreed to participate in the dispute resolution program provided by the European Data Protection Authorities Panel.