Privacy Policy

Introduction

HMS Vision Inc. values the protection and promotion of Personal Information privacy and the significant role that transparency and accountability play in the promotion of data subject rights.

To that end, this Privacy Policy has been adopted in relation to the collection, use, and dissemination of Personal Information.

This Policy applies only to HMS Vision Inc. In this Policy, the words “we” or “our” or “the Organization” refer to HMS Vision Inc.

This Policy has been developed with the recognition that technologies, processing purposes and categories of data processing may change over time due to regulatory requirements or as the nature of the Organization’s activities change. It may therefore be updated at any time. Where a material change is made to this Policy, the Organization will notify affected data subjects of such changes and inform them of the impact of such changes in relation to the processing of their Personal Information. A change will be considered ‘material’ when it has the ability to change the nature of the processing performed on a data subject’s Personal Information, therefore affecting an individual’s data subject rights.

In addition to the processing of Personal Information generally, it may be necessary for HMS Vision Inc. to collect and handle Sensitive Personal Information (SIP). Sensitive Personal Information relates to Personal Information that if leaked or illegally accessed or used, may have an impact on the individual rights of data subjects. The Organization will therefore take all adequate and reasonable measures to ensure that Sensitive Personal Information is not leaked or illegally accessed and that data subjects are informed of the processing of their Sensitive Personal Information by HMS Vision Inc.

Our Principles

In the processing of Personal Information, we will adhere to the following principles:

• We will ensure that information processing activities are lawful and comply with regulations and that they are fair, necessary and in good faith.

• We will promote purpose limitation by only processing the Personal Information needed to comply with the reasons for which it was collected, and that the minimum amount of Personal Information is processed.

• We will remain open and transparent in relation to the processing of Personal Information.

• We will strive to keep the Personal Information that we process accurate and complete.

• We will take reasonable measures to ensure the security of Personal Information and will remain accountable to data subjects.

• We will not retain Personal Information unnecessarily and will ensure that we have a legitimate reason for retaining Personal Information.

Legal Bases For Data Processing

Personal Information will be processed on based on one or more of the following legal bases:

• We may process Personal Information upon obtaining consent.

• We may process Personal Information where necessary for the performance of a contract to which the individual concerned is a party, or for associated purposes such as contract administration and performance review.

• We may process Personal Information where necessary for the performance of statutory responsibilities or obligations.

• We may process Personal Information where necessary for responding to a public health emergency or protecting the life, health, or property of individuals in cases of emergency.

• We may process Personal Information for the purposes of news reporting in the public interest and other activities in the public interest.

• We may process Personal Information already disclosed by the individuals themselves or otherwise lawfully disclosed.

• We may process Personal Information as permitted by applicable laws and regulations or as requested by a Judicial or Regulatory body.

An individual’s request for the deletion of its Personal Information or for the restriction or objection to the processing of its Personal Information may be overridden by an alternative legal bases for processing as permitted by the law or as instructed by a Judicial or Regulatory Body.

Definitions

Automated decision-making – refers to the use of computer programs to automatically analyze or assess individuals’ behaviors, habits, interests, or hobbies, or individuals’ financial, health, or credit status, etc.

Data Processing – Any operation or set of operations which is performed on Personal Information or on a set of Personal Information, irrespective of whether this involves automated means.

Data Subject – refers to any individual person who is human and who can be identified, directly or indirectly, via an identifier such as a name, an ID number, location data, or via factors specific to the person’s physical, physiological, genetic, mental, economic, cultural or social identity.

Overseeing Authority – refers to an authority has the power and responsibility to oversee compliance with legal obligations within that authority’s jurisdiction. The Overseeing Authority may have powers to enact legislation, conduct investigations and issue fines for non-compliance with the provisions which it is charged with overseeing.

Personal Information (“PI”) – Personal information is defined as any kind of information, electronically or otherwise recorded, related to an identified or identifiable natural person.

Sensitive Personal Information (“SPI”) – is PI that, if disclosed or illegally used, may cause harm to the security, property safety or dignity of natural persons. SPI includes information on biometric characteristics, religious beliefs, specific identity, medical health, financial accounts, individual location tracking, etc. Moreover, any PI of a minor under the age of 18 is regarded as SPI.

You/Your – An individual, living, human being whose Personal Information is subject to data processing due to their engagement, whether directly or indirectly with HMS Vision Inc. This individual may be a data subject.

Personal Data Disclosures

HMS Vision Inc. will not sell or trade Personal Information with any other entity. We use partners and service providers, payment processors, and analytics providers to perform services on our behalf and in order to forward the legal and legitimate processing of Personal Information needed for a particular purpose, such as for the performance of contractual obligations.

Personal Data may be disclosed to regulatory authorities or government bodies, as required by applicable law.

Personal Data may be disclosed to third parties as required in connection with claims, disputes, or litigation, when required by applicable law, or subject to our determination that disclosure is necessary to protect the health, safety, rights or property of individuals or entities, or to enforce our legal rights or contractual commitments.

HMS Vision Inc. will take reasonable measures to ensure that Personal Information is shared with reliable parties.

Cross-border data transfers and international data transfers

HMS Vision Inc. will ensure that it remains compliant with regulations in relation to the international transfer of Personal Information. HMS Vision Inc. will therefore enforce the following organizational controls where applicable, including but not limited to:

• Compliance with relevant adequacy decisions where these have been issued by an overseeing authority.

• Obtaining consent where consent forms the primary basis for information processing or where this is required by an overseeing authority.

• Use of standard, binding contractual clauses and binding corporate rules where these have been issued as guidance from an overseeing authority.

• Use of certification mechanisms and codes of conduct.

HMS Vision Inc. will ensure that all transfers of personal data to third countries are supported by adequate legal bases for processing.

HMS Vision Inc. will ensure that an adequate risk assessment has been conducted before authorizing the transfer of personal data to third countries.

HMS Vision Inc. will ensure that adequate technical and organizational security measures are in place where the international transfer of personal data is required.

We may transfer Personal Information internationally for legitimate and legal purposes, including but not limited to:

• When you expressly consent to the transfer.

• Pursuant to legal requirements, procedural requirements, litigation, or mandatory requirements of a competent government authority.

• In connection with the sale, assignment, merger, or other transfer of all or a portion of our business to another entity.

• For any other legitimate reason.

Security

HMS Vision Inc. will take appropriate legal, organizational, and technical measures to protect Personal Information, consistent with applicable privacy and data security laws. When a third-party service provider is retained, that provider will be carefully selected and required to use appropriate measures to protect the confidentiality and security of Personal Information.

In case of Personal Information security incidents, HMS Vision Inc. will activate emergency plans to prevent the expansion of security incidents and inform data subjects by emails, telephone calls, push notifications, announcements, and other forms, in a timely manner and in accordance with laws and regulations.

Data Retention and Integrity

HMS Vision Inc. will take reasonable measures to ensure that the Personal Information that is processed is reliable, accurate, and complete for its intended use, and is necessary to carry out the purposes for which it is collected and as described in this Policy.

HMS Vision Inc. may retain certain Personal Information even after the primary purpose for which the Personal Information was collected lapses. Certain Personal Information may be required for residual legitimate purposes, including for example, communication on future opportunities, providing a recommendation letter, processing an employment application once again, matters related to retiring benefits, handling any disputes and/or allowing the Organization to fulfill any of its contractual and/or statutory obligations.

Automated Means of Processing

In the event of automated processing of Personal Information, HMS Vision Inc. will ensure that its information processing activities are transparent, fair, and just and will ensure that no unreasonable differential treatment is associated with any decision-making processes. HMS Vision Inc. will ensure that data subjects are informed of any automated decision-making processing of their Personal Information.

Access and correction requests, questions and concerns, and methods and procedures to exercise data subject rights

For any questions, requests, or concerns about how HMS Vision Inc. processes Personal Information, please send an email to: [email protected]

If you are a data subject, the following rights are applicable and exercisable by you. You may use the e- mail above ([email protected]) if you want to exercise their rights including:

• Right to access to and copy your Personal Information;

• Right to withdraw your consent or opt-out of the processing of your Personal Information, however, the withdrawal may not necessarily impact any processing before the withdrawal;

• Right to require correction or supplementation of Personal Information;

• Right to request deletion of your Personal Information;

• The right to appeal a controller’s decision regarding a request previously made by the data subject.

• Right to be informed of automated-decision making and profiling

• The right to nondiscrimination for exercising any of the data subject’s rights.

• Any other rights provided under the law.

Data Processing on HMS Vision Inc. Websites

Data subjects can control the use of cookies and similar technologies by following the instructions on the respective Website Privacy Notice.

Security Measures On Our Websites

Our websites have security measures in place to protect the loss, misuse, and alteration of the information under our control. Due to the nature of Internet communications, no data transmission over the Internet can be guaranteed to be completely secure.

Children's Online Privacy

This website is intended for use by persons over the age of 18. HMS Vision does not seek to collect information about children under the age of 18. No information should be submitted to or posted on this website by users under 18 years of age. If you believe that we might have any information from a child under age 18, please contact us on [email protected].