GLOBAL PRIVACY POLICY

Last Updated: 16 July 2019

WILLWAY GLOBAL, LLC takes your privacy and security seriously. This Policy describes how WILLWAY GLOBAL, LLC (collectively “WILLWAY GLOBAL”, “we” or “us”) collect, use, transfer, and disclose your information.

This Policy covers information WILLWAY GLOBAL, LLC collects in connection with our Recruitment & Consulting Services, (collectively, the “Services”). This Policy also covers information collected through:

Websites we operate, which you are accessing this Policy (the “Site”),
Technical applications available for use on or through computers, mobile devices, social media (including the “Apps”),
Our social media pages and apps to Site links (collectively, our “Social Media Pages”), and
HTML-formatted email messages we send to you that link to this Policy (collectively, including
The Site, Apps, and our Social Media Pages, the “Online Systems”).

This Policy also covers other means by which we collect information. For instance, it also covers how we gather information from in person discussions, telephone conversations, video discussions, web-based webinar series and through non-electronic communications (i.e., collection through other means than our Online Systems).

WHO WE ARE
WILLWAY GLOBAL, LLC is an executive, retained search firm which partners with Pharmaceutical, Medical Device, Life Sciences, Healthcare and Natural Product organizations. Our Consultants have been serving best in class organizations for 20 years within 7 continents worldwide. WILLWAY GLOBAL's talent acquisition reach spans across all Corporate Verticals, R&D, Commercial, Consulting, RPO, Start-up, Turn-around and PE organizations ranging from $500 Million to $50 Billion. Therapeutic areas include: Anti infectives, CNS, Diabetes, Endocrinology, Gastroenterology, Immunology, Metabolic Disease, Neurology, Neuroscience, Oncology, Orphan Disease (aka Rare Disease), Rheumatology, Urology, Vaccines and Virology.

Mission: Build best in class organizations while developing people

Vision: Produce win-win outcomes each and every time

Values: Serve our clients and candidates through trust, authenticity and our core philosophy

“Where there’s a WILL there’s a WAY, a simple concept with high impact.” - Josephine Tatone, President & CEO

WILLWAY GLOBAL LLC offers services to help companies recruit and attract talent
(“Recruitment Services”). We provide Recruitment Services to clients searching for talent at the board-level, chief executive, and other senior executive and leadership positions. Our team also offers project recruitment services to help clients attract best in class talent within the meaningful industries.

WILLWAY GLOBAL LLC partners with the best in industry to conduct assessments, participate in surveys and career coaching, conduct compensation and benefits analysis (where permitted by law), and facilitate the recruitment process (“Products”). Our clients may be your employer or an organization with which you are seeking employment.

PERSONAL INFORMATION WE COLLECT
WILLWAY GLOBAL, LLC collects information that identifies you as an individual or relates to an identifiable individual (“Personal Information”) to provide Services to you, our clients and to operate our business. The type of Personal Information we collect about you depends on the situation and need. Please do not provide us with any Personal Information if you do not agree with this Policy.

HOW WE COLLECT PERSONAL INFORMATION
As you interact with WILLWAY GLOBAL, LLC you provide some Personal Information
directly. Personal Information about you may also come from our clients to whom we provide Services. We may also obtain Personal Information about you from third parties. We use third- party companies to handle assessments, and other products featured on our Online Systems as well as event registration. If you wish to purchase a service, product or register for an event, you may be directed to a webpage that is hosted by the third party (i.e. Eventbrite, other similar technology, or its service providers) and not by WILLWAY GLOBAL, LLC.

HOW WE USE PERSONAL INFORMATION WE COLLECT

WILLWAY GLOBAL, LLC uses the Personal Information it collects in several ways. The summary below provides additional information regarding the ways we use Personal Information we collect.

We use your Personal Information to provide our Services.

We use Personal Information to render Services to you and our clients and candidates. We do this to fulfill our contractual obligations, maintain relationships with our clients and candidates and where we have a legitimate, beneficial interest in using Personal Information to conduct our business. In the course of our Recruitment Services, we may use Personal Information that we have collected to compose a profile about you. This profile may be used to identify employment opportunities we think may be of interest to you.

You can always decline to our creating a profile about you, see the ‘Choices and Access’ section below on how you can decline. In the course of our Recruitment Services, we also use your Personal Information to confirm references and complete education and background checks as appropriate. We use your

Personal Information to respond to your questions, to verify your information, or to send information to you. From time to time we use your Personal Information to share important information regarding the Online Systems, changes to our terms, conditions, policies, and other administrative, industry and community updates. We use your Personal Information to operate our business.

We use your Personal Information for our business obligations, such as audits, internal communication regarding candidates and clients, determining the effectiveness of our initiatives, administering our Services, maintaining and securing our infrastructure, and for procurement and financial transactions.

We may use Personal Information to conduct analytics and thought leadership materials.

We perform analytics because we have a legitimate beneficial business interest in doing so, to better serve you.

We may retain and use Personal Information about you for research, publication, development, benchmarking and norms, validation, longitudinal studies, trend analysis, to improve our Services or to develop and market new Services. We may use Personal

Information about you to ensure that our Services follow legal requirements such as equalopportunity laws.

We may use your Personal Information to send you information, data or marketing materials. WILLWAY GLOBAL LLC sends informational e-mails, articles, white papers, proposals, engagement letters, and information regarding our Services and products. We also use your Personal Information to conduct surveys.

WHO HAS ACCESS TO YOUR PERSONAL INFORMATION

How your Personal Information is disclosed will depend upon the situation and need. We use your Personal Information to provide our Services. While providing our Services, we may disclose your Personal Information to clients who have engaged our services.

As a global firm, we have partnerships around the world. To the extent permitted by law, we may share Personal Information with our partnerships to provide uninterrupted Services for you our clients and candidates. WILLWAY GLOBAL LLC is responsible for managing jointly-used Personal Information.

From time to time, we also disclose Personal Information to our strategic partners and to our network of independent consultants who provide services on WILLWAY GLOBAL LLC’s behalf for the above stated purposes. WILLWAY GLOBAL LLC discloses Personal Information to third parties who provide support for our Services or business operation.

WILLWAY GLOBAL LLC may disclose or transfer all or part of your Personal Information in the event of a sale of our company. We may also disclose or transfer all or part of your Personal Information in the event of a merger or consolidation involving our company. This may also occur if there is a sale or transfer of assets or of any portion of our business. There may be other times that we disclose your Personal Information.

OTHER INFORMATION WE COLLECT

WILLWAY GLOBAL LLC collects other information that does not reveal your identity (“Other Information”), such as:

Information gathered through cookies, pixel tags, and other technologies
App usage information
Demographic information and other information provided by you
Aggregated information.

Since Other Information does not reveal your specific identity, we may use it for any purpose. Also, if we combine Other Information with Personal Information that identifies you directly (like combining your name with your location), we will treat the combined information as Personal Information, as long as it is combined. If we are required to consider Other Information as Personal Information under applicable law, we may use and disclose it as detailed in this Policy.

We and our third-party service providers may collect Other Information in a few of ways. We use “cookies” and other similar technologies to help us determine information such as, the type of content a visitor to the Site consumes, and the length of time each visitor spends at any area of the Site. Cookies and other similar technologies enhance your experience on the Site and allows us to better understand your needs. Please see WILLWAY GLOBAL LLC’s cookie policy (Insert WILLWAY weblink) for more information about our use of cookies.

You can configure your browser settings to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie(s) from a particular site. If you disable cookies and similar technologies, your experience on the Site may be reduced and some features may not work as intended.

ADDITIONAL GUIDELINES

WILLWAY GLOBAL LLC may on occasion sponsor special features, events or promotions on the Online Systems and additional privacy information may be posted. Depending on the nature of the Service being used, your location, or our contract with our client that may have asked you to participate in a Service, you may be asked to consent to the collection, use, transfer, and disclosure of your Personal Information. You may also be given a privacy notice before participating in a Service. This privacy notice, to the extent it conflicts with this Policy, will govern that particular Service, feature or promotion.

CHOICE AND ACCESS

Click here to request access to your data.

Attn: Privacy Officer (Include within subject line)

Include your direct contact information with body of message.

Personal Information to us is voluntary, although if you do not provide certain Personal

Information you may not be able to participate in our Services.

ask how we handle your Personal Information,
withdraw your consent to our use of your Personal Information,
object to our use of your Personal Information for our legitimate business interests or needs, to serve you best, or
request an electronic copy of your Personal Information for purposes of transmitting it to others (to the extent this right to data portability is provided to you by applicable law),
request to review, correct, update, hold or restrict the use of your Personal
If you would like to opt-out of receiving marketing communications from us, please contact us at www.willwayglobal.com/contact to have your contact information removed from our databases.

LOCATION OF PERSONAL INFORMATION COLLECTED AND MAINTAINED

Depending on the Product or Service we are providing to you, your Personal Information may be used, processed, disclosed, and transferred to and within the United States and other countries where we have facilities or in which we engage contracted service providers. When using our Online Systems, Services, or partner services, you understand that your Personal Information may be transferred to countries outside of your country of residence, which may have different data protection rules than your country.

SECURITY

WILLWAY GLOBAL LLC has reasonable organizational, technical, and administrative measures in place to protect against loss, misuse, and alteration of Personal Information about users of the Online Systems which is under our control. Unfortunately, no security system or system of transmitting information over the Internet can be 100% guaranteed, to be secure. Which is also the case within your very own organization.

RETENTION PERIOD

We keep your Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained.

LINKS TO OTHER WEBSITES

This Policy does not address, and we are not responsible for, the privacy, information, or other practices of other third parties.

UPDATES TO THIS POLICY

WILLWAY GLOBAL LLC reviews its privacy practices often, and those practices are subject to change. You can identify when this Policy was last revised and updated by checking the “Revised Date”. This can be found at the bottom of the Policy. Any changes to the Policy will be posted on the Internet and accessible through the Site.

USE OF ONLINE SYSTEMS BY CHILDREN

The Online Systems are not intended for individuals under the age of sixteen (16). We request that these individuals do not provide their personal information through the Online Systems.

SUMMARIES OF POLICY

This Policy is the only authorized statement of WILLWAY GLOBAL LLC’s practices regarding online collection of Personal Information through Online Systems and the usage of Personal Information. Any summaries of this Policy generated by third party software or otherwise have no legal effect, are in no way binding upon WILLWAY GLOBAL LLC, and cannot be relied upon in substitute for this Policy, and neither supersede or modify this Policy.

QUESTIONS

WILLWAY GLOBAL LLC is responsible for collection, use, and disclosure of your Personal Information under this Policy.

Please submit questions regarding this Policy to WILLWAY GLOBAL LLC at www.willwayglobal.com/contact. Attn: Privacy Officer

ADDITIONAL INFORMATION REGARDING THE EEA

You may also submit a complaint or report an alleged infringement of applicable data protection law with a data protection authority for your country or region, or where an alleged infringement of applicable data protection law has taken place.