Morningside Privacy Notice

Effective Date: [9/6/2018]

This Privacy Notice applies to Morningside’s processing of Personal Data in connection with:
• Your use of our website (www.morningtrans.com);
• Subscriptions to our newsletters and other marketing messages;
• Invitations to and participation in our events; and
• Recruitment processes.

MORNINGSIDE AS DATA CONTROLLER:

“Morningside” refers to one of the following entities: Morningside Translations, LLC (US), AC Translations Limited (UK), Morningside GmbH (Germany), and Morningside Translations Israel Ltd. (Israel) (each, an “Entity” or together, “Entities”).

We provide this Privacy Notice on behalf of each Morningside Entity. The data controller (“we”, “us”, “our”) is the Entity named when we collect your Personal Data or in the location where Morningside referred you to this Privacy Notice. If no Entity has been clearly identified, the data controller or data controllers may be identified as follows:

• For Personal Data that Morningside collects on or through its websites, Morningside Translations, LLC is the data controller.
• For Personal Data that is collected in connection with our newsletters and other marketing messages, the data controller is the sender of the message unless otherwise identified.
• For Personal Data collected in connection with invitations and participation in our events, the data controller will be the Entity that is organizing such event as identified in the invitation.
• For Personal Data collected in the context of a recruitment process, the data controller is the Entity identified in the job posting or otherwise seeking to source a position.

If you have any doubt about the controller or controllers of your Personal Data, please contact us using the information in the section “Contact us” at the end of this Privacy Notice.

PERSONAL DATA WE PROCESS:

“Personal Data” refers to any information that relates to you directly or indirectly. We process the following categories of Personal Data:

• Contact information, such as your name, address, email address, phone number, social media handles, and business contact information;
• Technical information, such as data collected about your interaction with our websites and email communications;
• Financial information, such as payment card and related information;
• Recruitment information, such as curriculum vitae/resume, work history, and qualifications;
• Identification or background information provided by you or collected by us or third parties as part of our recruitment, engagements, business analysis, and related processes; and
• Any other information that you provide us that can be used to identify you.

We collect Personal Data from:

• Direct interactions, such as when you inquire about our services, provide us your contact details, register for our events, participate in surveys or questionnaires, subscribe to newsletter and blog updates, post comments on our blogs, or in any way engage with us or our personnel;
• Cookies and automated technologies, such as when you interact with our website or click on links on our emails;
• Through social media, such as if you link to social media platforms or use social media plug-ins (depending on your user privacy settings on that social media platform); and
• Third party sources, such as when we need to collect your Personal Data from publicly available sources.

In addition to Personal Data, we may collect other information about how you use our website that alone cannot be generally used to identify you. For example, we may collect your browser, device, and operating system information. If any of this information can be used to identify you because, for example, we link it to your Personal Data, we will treat such information as Personal Data.

HOW WE USE YOUR PERSONAL DATA:

Below is a description of the Personal Data we collect, the likely source of the Personal Data, how we may use it, and for what purposes and pursuant to what legal basis.

Any other purposes for which we wish to use your Personal Data that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you by amending this Privacy Notice in accordance with the Section titled “Changes to this Privacy Notice” below.

HOW WE SHARE YOUR PERSONAL DATA:

We will share your Personal Data within Morningside, at your direction, as disclosed to you at the time of collection, or in the following circumstances:

• Service Providers: We may provide your Personal Data to our services providers that help us run and manage our organization and process Personal Data solely on our behalf. The categories of service providers include: technology, analytics, marketing and recruitment service providers, and credit card processors.
• Corporate Transaction: In the event Morningside is involved in a merger, reorganization, acquisition or sale of all or a portion of its assets, or other corporate transaction, we may disclose your Personal Data as part of that transaction.
• As Required By Law: We may disclose your Personal Data if we determine that the disclosure is necessary: (i) to comply with any law applicable to us, lawful requests from law enforcement or a regulatory agency (including to meet national security or law enforcement requirements), or to comply with other legal processes; (ii) to protect the legitimate rights, privacy, property, interests or safety of Morningside, our business partners, personnel, or the general public; (iv) to pursue available remedies or limit damages; (v) to enforce our Terms of Use; or (vi) to respond to an emergency.

INTERNATIONAL TRANSFER OF PERSONAL DATA:

Morningside is committed to complying with this Privacy Notice and the data protection laws, including those outside of the United States, that apply to our collection and use of your Personal Data. The laws in the United States may not be as protective as the laws in your country. Because of this, Morningside has taken steps to protect your privacy and fundamental rights when your Personal Data is transferred to the United States.

As described in our Privacy Shield certification, we comply with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use and retention of Personal Data from European Union member countries and Switzerland, respectively. Morningside Translations, LLC has certified that it adheres to the Privacy Shield Principles. Morningside Translations, LLC remains responsible for any of your Personal Data that is shared under the Onward Transfer Principle with third parties for external processing on our behalf, as described in the “How We Share your Personal Data” section. To learn more about the Privacy Shield program, and to view Morningside Translations, LLC’s certification, please visit the Privacy Shield website. If there is any conflict between the terms of this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern with regard to the Personal Data received in reliance on the Privacy Shield. For more information about the Privacy Shield Framework, visit www.privacyshield.gov.

If you have an inquiry regarding our privacy practices in relation to our Privacy Shield certification, we encourage you to contact us. Morningside Translations, LLC is subject to the investigatory and enforcement powers of the US Federal Trade Commission. You may also refer a complaint to your local data protection authority and we will work with them to resolve your concern.

In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means. We have committed to refer unresolved Privacy Shield complaints to JAMS Privacy Shield Program, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit www.jamsadr.com for more information or to file a complaint. The services of JAMS are provided at no cost to you.

COOKIES AND OTHER DATA COLLECTION TECHNOLOGIES:

A “Cookie” is a small text file that is sent to or accessed from your web browser or your computer’s hard drive. A Cookie typically contains the name of the domain (internet location) from which the Cookie originated, the “lifetime” of the Cookie (when it expires), and a randomly generated unique number or other similar identifier. A Cookie may also contain information about your computer, such as user settings, browsing history and activities conducted while using our online services.

A “Web Beacon” (also called a “pixel tag” or “clear GIF”) is a piece of computer code that enables us to monitor user activity and website traffic.

We refer to Cookies, web beacons (also known as pixel tags and clear GIFs) and other similar technology as “Data Collection Technology.” To learn more about cookies and web beacons, visit www.allaboutcookies.org.

Data Collection Technology helps us improve your experience on our online services. For example, we use Google Analytics, a web-based analytics tool that tracks and reports on the manner in which the website is used to help us to improve it. Google Analytics does this by placing Cookies on your device. The information that the Cookies collect, such as the number of visitors to the website, the pages visited and the length of time spent on the website, is aggregated. We also may use Data Collection Technology to collect information from the computer or device that you use to access our online services, such as your operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located.

We generally use the following types of Data Collection Technologies, which may change from time to time:

Your Control of Cookies: Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject Cookies or alert you when a Cookies is placed on your device. You may also be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept Cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through our online services.

Our Policy on Do Not Track Signals: Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Because DNT signals are not yet uniform, our website and many other websites do not currently honor DNT signals.

LINKS TO THIRD PARTY WEBSITES AND SERVICES:

When interacting with us, you may come across links or references to third party websites and services that we do not operate or control. If you provide your Personal Data to that third party through its websites or services, you will be subject to that third party’s privacy practices and policies. This Privacy Notice does not apply to Personal Data that you provide to a third party website or service. A link or reference to a third party website or service does not mean that we endorse that third party or the quality or accuracy of the information on its website or service.

SECURITY:

We implement appropriate technical and organizational measures designed to ensure your Personal Data in protected from unauthorized access, use, disclosure, alteration or destruction, in accordance with applicable laws and regulations. For example, we limit our collection and use of your Personal Data to the extent necessary to provide you with our services. We also use encryption protocols to secure the transit of certain information to our servers. If you would like to know more about how we protect your Personal Data, you can contact us using the information in the section “Contact Us” at the end of this Privacy Notice.

RETENTION OF PERSONAL DATA:

We will keep your Personal Data for as long as necessary to fulfill the purposes for which we collected it, including any legal, accounting or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, whether we can achieve those purposes through other means, and all applicable legal requirements.

CHILDREN’S PRIVACY:

Our services are not directed to or intended for use by minors. Consistent with the requirements of the US Children’s Online Privacy Protection Act, the GDPR, and all other applicable laws and regulations, if we learn that we have received information directly from a child under age 16 without his or her parent or legal guardian’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our services. Subsequently, we will delete such information.

MARKETING:

If you do not wish to receive marketing-related emails from us, please click the unsubscribe link at the bottom of a marketing email, or email us using the information in the section “Contact Us” at the end of this Privacy Notice. If you choose to unsubscribe from all marketing emails, that unsubscribe request will apply across all Morningside Entities. Please note that even if we stop all marketing communications, you may still receive administrative, legal, and other important communications from us.

YOUR RIGHTS:

You may access and modify the Personal Data we maintain about you by contacting us using the contact information below. We will respond to your inquiry within a reasonable timeframe.

Individuals in the European Economic Area: If you are located in the European Economic Area (“EEA”) and we maintain your Personal Data, you have the following additional rights (under the EU General Data Protection Regulation) with regard to your Personal Data:

• Right to access and receive: You may request a copy of or access to the Personal Data we hold about you. You may also request that we transfer your Personal Data to a third party in a machine-readable format.
• Right to correct: You may ask us to update or correct inaccurate or incomplete Personal Data we hold about you.
• Right to limit or restrict: You may have the right to request that we stop using all or some of your Personal Data or to limit our use of it. You also have the right to withdraw your consent to those Personal Data processing activities for which you have given us your consent.
• Right to erase: You may have the right to request that we delete all or some of your Personal Data.
• Right to withdraw consent: You have the right to withdraw any consent you have previously given to Morningside at any time. Your withdrawal of consent does not affect the lawfulness of our collecting, using, and sharing of your Personal Data prior to the withdrawal of your consent. Even if you withdraw your consent, we have the right to use your Personal Data if it has been fully anonymized and cannot be used to identify you.

If you wish to exercise any of your rights above or advise us of any changes to your Personal Data, please contact us using the information in the “Contact Us” section at the end of this Privacy Notice. We may charge you a reasonable fee if you request additional copies of your Personal Data or make other requests that are manifestly unfounded or excessive. If we are unable to honor your request, or before we charge a fee, we will let you know why.

Please note that if you decide to exercise some of your rights, we may be unable to provide you certain services, or you may not be able to use or take full advantage of the services we offer.

SPECIAL NOTICE TO CALIFORNIA RESIDENTS:

California Civil Code Section 1798.83 permits individual California residents to request information about our disclosure of certain categories of Personal Data to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us using the information in the section “Contact Us” below. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this Section.

CHANGES TO THIS PRIVACY NOTICE:

The Effective Date of this Privacy Notice is set forth at the top of this webpage. If we materially change the way we collect, use or disclose your Personal Data we will notify you in advance by email and/or by placing a prominent notice on this website. The amended Privacy Notice supersedes all previous versions.

CONTACT US:

We welcome your questions and comments about this Privacy Notice or how we process your Personal Data. We will route your questions and comments to the appropriate data controller.

Morningside
450 7th Ave #1001
New York, NY 10123
1-877-231-1222
[email protected]

You always have the right to lodge a complaint with your local competent supervisory authority or any authority that applies to the Morningside Entities.