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Morningside Translations, Inc. Privacy Policy

Morningside Translations, Inc. respects individual privacy and values the confidence of its clients, employees, subcontractors, vendors, business partners and others. Not only does Morningside strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Privacy Policy (the “Policy”) sets forth the privacy principles Morningside follows with respect to transfers of personal information from the European Union.

In compliance with the Privacy Shield Principles, Morningside Translations commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Morningside Translations at:

Uri Burger
VP of Corporate Development
[email protected]
212-643-8800

Morningside Translations has further 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 https://www.jamsadr.com/  for more information or to file a complaint.  The services of JAMS are provided at no cost to you.

SCOPE

This Policy applies to all personal information received by Morningside and Morningside Translations Rochester in any and all formats.  Morningside will ensure that all global data handled by our offices conforms to this Privacy Policy.

Morningside complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  (Your organization name) has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

PRIVACY PRINCIPLES

The privacy principles in this Policy have been developed based on the Privacy Shield Principles.

NOTICE: Where Morningside handles personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which Morningside discloses that information, the choices and means, if any, Morningside offers individuals for limiting the use and disclosure of personal information about them, and how to contact Morningside. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Morningside, or as soon as practicable thereafter, and in any event before Morningside uses or discloses the information for a purpose other than that for which it was originally collected. Morningside may disclose personal information to its network of translators for the purposes of translation.

Morningside is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Under certain conditions, there is the possibility for an individual to invoke binding arbitration.

Morningside’s third party suppliers are obligated to provide at least the same level of privacy protection as is required by the Privacy Shield Principles. Morningside takes the appropriate steps to ensure that its suppliers effectively process the personal information transferred in a manner consistent with the organizations obligations under the Principles.

Where Morningside receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: Morningside will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, Morningside will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Morningside will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY: Morningside will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Morningside will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS: Morningside will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Privacy Shield or being subject to another European Commission finding. Where Morningside has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Morningside will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, Morningside will grant individuals reasonable access to personal information that it holds about them. In addition, Morningside will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY: Morningside will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: Morningside will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Morningside determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: With respect to complaints related to our Privacy Policy that cannot be resolved through our internal Corrective/Preventive Action Process, we agree to cooperate and comply with the independent recourse mechanism dispute resolution procedures established by JAMS to investigate all unresolved complaints, regardless of the type of data involved.

In compliance with the Privacy Shield Principles, Morningside Translations commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Morningside Translations at:

Uri Burger
VP of Corporate Development
[email protected]
212-643-8800

Morningside Translations has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.  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 the EU DPAs for more information or to file a complaint.  The services of EU DPAs are provided at no cost to you.

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by Morningside to these policy principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

CHANGES TO THIS PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield Principles. A notice will be posted on Morningside IP’s web page: www.morningtrans.com

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