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Privacy Shield Policy

PRIVACY SHIELD POLICY

In accordance with our commitment to protect personal privacy, Market Resource Partners (“MRP”) comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from European Union and Switzerland to the United States respectively. MRP has certified to the Department of State that it adheres to the Privacy Shield Principles (“Principles”). If there is any conflict between this Policy and the Privacy Shield Principles, then the Privacy Shield Principles shall prevail. To learn more about the Privacy Shield Program and to view our certification, please visit https://www.privacyshield.gov/welcome.  A list of participants can be found at https://www.privacyshield.gov/list.

The Federal Trade Commission (FTC) has jurisdiction over MRPs compliance with the Privacy Shield.

All MRP employees who handle Personal Data from Europe and/or Switzerland are required to comply with the Principles stated in this Policy.

SCOPE OF THIS PRIVACY SHIELD POLICY

This Policy applies to the processing of Personally Data that MRP receives or collects in the United States or transfers to the United States concerning Individuals who reside in the European Union or Switzerland.

This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)

COLLECTION AND USE OF PERSONAL DATA

We receive and collect Personal Data such as name, job title, telephone numbers, e-mail addresses, and postal addresses from visitors to our website when they (i) submit inquiries or requests to us, (ii) become registered users of the website, (iii) sign up to receive newsletters or bulletins from us, or (iv) choose to provide information to us for some other reason. The personally identifiable information that we collect may vary based on the individual visitor’s interaction with our website and request for our services.

We may obtain Personal Data about visitors from our subsidiary companies, business partners, vendors or Clients. We may add this data to information that they have previously provided to us in order to serve them better. From time to time, we may compare our contact lists to lists received from our subsidiary companies, third party service providers or Clients to try to avoid sending visitors unwanted, unnecessary or duplicative messages. We may also utilize and incorporate information from other sources to update and supplement information concerning visitors. All such combined, updated, and supplemented information will be handled consistent with this Policy.

Any personally identifiable information provided will be used by us in connection with providing services for visitors and in order to process any requests or inquiries that they initiate.

DISCLOSURES AND ONWARD TRANSFERS OF PERSONAL DATA

In order to operate our websites and provide services, we may provide personal, aggregate and other associated data to third parties including our services providers and vendors that provide or perform services for us, including services such as payment processing, database management, and professional services. MRP discloses Personal Data only to third parties who reasonably need to know such data for the scope of the initial transaction and not for other purposes.

Such third parties must agree to use the personal data only for the purpose for which they have been engaged by MRP and confirm that their privacy practices are consistent with this Policy.

On occasion, we may also share Personal Data concerning a visitor with our affiliates (such as a subsidiary or affiliate of our company) and Clients in furtherance of our operations and as needed to implement visitor request.

We remain responsible for the Personal Data that we share with third parties for processing on our behalf, and we remain liable under the principles if such third parties process such Personal Data in a manner inconsistent with the principles and we are responsible for the event giving rise to the damage.

Please be aware that MRP may be required to disclose Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

SENSITIVE DATA

MRP does not collect any Sensitive Data

CHOICE

We offer individuals the opportunity to choose (opt-in) whether their personally identifiable Information is (i) to be disclosed to a third party, (other than to an agent performing tasks on our behalf as mentioned above) and pursuant to our instructions, or (ii) to be used for a purpose that is materially different than the purpose for which it was originally collected or subsequently authorized by the individual. You can update your account preferences, by using the unsubscribe mechanism or other means provided within the communications that you receive, or by contacting us directly at privacy@mrpfd.com.

DATA INTEGRITY AND SECURITY

MRP uses reasonable efforts to maintain the accuracy and integrity of personal data and to update it as appropriate. MRP follows generally accepted industry standards and has implemented physical and technical safeguards to protect personal data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, MRP’s systems use firewalls and Secure Socket Layers to help protect and safely transmit information.

ACCESS TO PERSONAL DATA

Data Subjects have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which MRP collected it. Upon reasonable request and as required by the Privacy Shield principles, Data Subjects are allowed  access to their Personal Data, in order to correct, erase, amend or block any data that is incorrect. In the event that you wish to access, change or update your information please contact: privacy@mrpfd.com and we will endeavour to respond to your request within 45 business days.

Please note that where MRP are acting as a processor of personal data for an MRP Client, MRP may first refer your request to the Client that submitted your personal data, and MRP will assist the Client as needed in responding to your request.

COMPLAINTS PROCEDURE

In compliance with the Privacy Shield Principles, MRP is committed to resolving complaints regarding the collection and use of your Personal Data. Should you wish to make a complaint regarding this Policy or the use of your Personal Data, please contact: privacy@mrpfd.com. MRP will respond to you within 45 days of receiving your complaint.

If the issue cannot be resolved through our internal processes, you may file a claim (free of charge) with PrivacyTrust, an independent U.S. alternate dispute resolution provider, at www.privacytrust.org.

If you have a complaint left unresolved by all available recourse mechanisms, you may invoke binding arbitration. Additional information is available here: www.privacyshield.gov/article?id=ANNEX-I-introduction.

CHANGES TO THIS POLICY

This Policy may be amended from time to time, consistent with the Principles and applicable data protection and privacy laws. If we make any material changes we will notify visitors by means of a notice on our website prior to the change becoming effective. We encourage visitors to periodically review this page for the latest information on our privacy practices.

DEFINED TERMS

For the purposes of this Policy, the following terms have the following meaning;

Data Subject” means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics.

Personal Data” as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual’s name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available.

Sensitive Data” means Personal Data that discloses a Data Subject’s medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.

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