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Morningside IP Privacy Policy

Privacy Policy

Morningside IP 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 Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles Morningside follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway).

SAFE HARBOR

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “U.S.-EU Safe Harbor”). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). Consistent with its commitment to protect personal privacy, Morningside adheres to the principles set forth in the U.S.-EU Safe Harbor (the “Safe Harbor Principles”).

Morningside IP complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  Morningside Translations has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view Morningside IP’s certification, please visit http://www.export.gov/safeharbor

Any questions about Morningside’s Privacy Policy or for a more detailed description of Morningside’s privacy compliance efforts please contact our Privacy Officer, Samuel Wu (swu@morningtrans.com) or by telephone at 212-643-8800.

SCOPE

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

PRIVACY PRINCIPLES

The privacy principles in this Policy have been developed based on the Safe Harbor Principles.

NOTICE: Where Morningside collects 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.

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 Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive) 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 the EU Data Protection Authorities (DPAs) to investigate all unresolved complaints, regardless of the type of data involved.

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by Morningside to these Safe Harbor 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 SAFE HARBOR PRIVACY POLICY

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

EFFECTIVE DATE:  SEPTEMBER 4, 2014