Morris McLane Limited (collectively referred to as “the Company”).

At the Company, we are strongly committed to protecting privacy.

As part of our commitment, we strive to protect the privacy of visitors to the sites that we operate (collectively, the “Site”). You can navigate the majority of the Site without giving us any personal information which identifies you. However, sometimes we need additional information about you in order to provide you with information or services you want to receive from us. Also, this Site provides a variety of interactive features which provides you with a public forum through which you have the ability to provide information about yourself to the Company and others.

In this digital world, privacy is important to the Company and should be important to you. The Company believes in transparency and we provide this notice so that you can understand our online information practices and the choices you can make about the way your information is collected and used.

The Information We Collect and Process

The Company collects and processes two basic types of information:

• Personally identifiable information: This is information that personally identifies one individual from another or enables you to be individually contacted (for example, names, e-mail addresses and other contact information). This information is voluntarily provided to us by Site visitors and is used by us for the purpose of responding to user submissions and fulfilling requests for further information about our services.
• Aggregate user and tracking information: This information gives us insights on how Site visitors use our site. This data is anonymous and does not contain any personally identifiable information. We use this information to ensure that our website, e-mails and marketing efforts continue to appeal to Site visitors and clients.

Information you voluntarily provide to Company

The Company only collects personally identifiable information that you voluntarily provide, for example, when you use our “contact us” feature, sign up for a newsletter, set up a voluntary user profile to post content within our forums or interactive features. Examples of such personally identifiable information that you provide to us may include, among other information, your name, physical address and email address. Under such circumstances you consent to our use/processing of the information you provide consistent with this policy.

Other information the Company collects/processes

Our Site may use technologies such as “cookies” to provide visitors with tailored information upon each visit. Cookies are a common part of many commercial websites that allow small text files to be sent by a website, accepted by a web browser and then placed on your hard drive as recognition for repeat visits to the Site. Every time you visit the Site, our servers, through cookies, pixels and/or GIF files, collect basic technical information such as your domain name, the address of the last URL visited prior to clicking through to the Site, and your browser and operating system. We may also use third party analytical tools (e.g. Google Analytics) to analyze activities on the Site and use of the Site. You do not need to enable cookies to visit the Site; however, some parts of the Site and some services may be more difficult or impossible to use if cookies are disabled. Some Company cookie files remain on your computer’s hard drive unless and until you manually delete the file. The Company cookie files do not contain personally identifiable information.

The Way We Use Information

We store the personal information you provide in a secure database in order to provide you with the information, products, and/or services you request and may be used to provide you with additional information about our services we believe may be of interest to you. The information is stored for a time period and in a manner relevant to responding to your request unless you request that it be removed. The information you provide us will be shared with the Company employees and service providers to the extent necessary to administrate our systems and/or accommodate your request.

For example, if you provide your name, mailing address, telephone and/or email address and request more information about the Company’s services, this information will be shared with appropriate Company personnel to fulfill your request. This information will not be shared with non-affiliated third parties without your consent.

We use non-identifying and aggregate information about the use of the Site to improve the navigation, content, and design of the Site. This information may include, for example, the most and least requested pages, analyzing traffic regarding specific features, and the number of users from the U.S. and other countries, among other things.

The Company complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. When personal information is transferred to outside service providers, it is done under a contract which requires the companies to use the shared information only for the limited purposes for which it is provided to them in providing services to The Company, and to agree to hold the information securely and confidentially in accordance with this privacy policy, applicable law and any applicable Privacy Shield privacy principles (see Users Located in European Union below).

The Company will not sell or distribute personally identifiable information collected from you outside of the Company without your consent (subject to the limited exceptions stated in this policy).

Promotions

We may operate contests, sweepstakes or other promotions through the Site, which may require registration in order to enter. Your personally identifiable information may be used by us to contact you for winner notification, prize delivery confirmation or other promotional purposes. Your entry in the contest or sweepstakes may also result in your being added to our mailing lists as well as those of our promotional partners or clients associated with the contest or sweepstakes. Acceptance of a prize may require you (unless prohibited by law) to allow us to post publicly some of your information on the Site, such as in social media or on a winner’s page, in the event you win a contest or sweepstakes.

Surveys or Voting

From time-to-time we may request personally identifiable information from you via surveys or voting polls. Participation is voluntary, and you will have the opportunity to decide whether or not to disclose information. At times, you may have to register to vote or to take part in a survey.

Exceptions

The Company may preserve and has the right to disclose any information about you or your use of the Site without your prior permission if the Company has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of the Company or its clients or their respective partners, employees, affiliates, other users of the Site, or the public; (b) enforce the Terms of Use for the Site; or (c) respond to claims related to your use of the Site. We may also disclose information as we deem necessary to satisfy any applicable law, regulation, legal process or lawful governmental request (including to meet national security or law enforcement requirements) or in the event of a sale or potential sale of the Company or one of its business units.

Interactive Areas

The Site provides interactive areas, such as chat rooms, forums and message boards available to its users. You are not required to provide any personal information when using these areas, but you may choose to do so. We strongly recommend that you DO NOT use your personal information as your user name and DO NOT post any personally identifiable information on line, since such information will be publicly available. We cannot ensure the security of any information you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose personal information in these areas.

Data Security

The Company understands that the safety of your personal information is extremely important to you. Accordingly, the Company uses reasonable technological, physical and other measures to keep your information protected from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal information. Due to the nature of the Internet and related technology, we cannot guarantee the security of your personal information and the Company expressly disclaims any such obligation.

Children’s Privacy

The Company understands the need to protect the privacy of children. The Site is not intended for use by individuals under 13 years of age. The Company does not knowingly collect or maintain personal information from children under the age of 13 at our Site.

How You Can Access or Correct Your Information

You may access, update or remove the information you provided to us by contacting us – see “How to Contact Us” below. Upon receiving your email with the request to update or remove your information, our privacy team will: 1) log the receipt of your request, including the date and time received; 2) take reasonable steps (including seeking additional information or documentation) to verify your identity, 3) evaluate the request (including, to the extent necessary, contacting the appropriate data holder); 4) once the evaluation is completed, take action consistent with the evaluation; and 5) respond to your request accordingly. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business. Information stored as part of this backup process will be deleted in due course on a regular schedule.

Links to Other Websites

Our Site contains links to other websites. The Company is not responsible for any websites that it does not own or operate. You should carefully review the privacy policies and practices of other websites that you link to from the Site, as we cannot control or be responsible for their privacy practices.

International Users

Information provided through this Site may be uploaded to a cloud and transferred to or accessed globally. By providing information to this Site, you consent to the transfer, processing and/or use of the information globally throughout the Company. Wherever the information is transferred or accessed within the Company it will be processed and used in accordance with this privacy policy.

Users Located in the European Union

The Company has self-certified with the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries in connection with the Privacy Shield Principles as part of the Privacy Shield program. To learn more about the Privacy Shield program, and to view the Company’s certification, please visit http://www.privacyshield.gov.

Internal and Independent Recourse Mechanisms

In compliance with the Privacy Shield Principles, the Company commits to resolve complaints about our collection or use of your personal information. The Company is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. Further, with respect to citizens to the European Union the Company has agreed to cooperate in investigations by, and comply with the advice of, the Federal Trade Commission and appropriate EU data protection authorities (“DPA”) in managing and resolving any dispute or complaint and provide the relevant DPA with written confirmation of the action taken. If you have questions or complaints regarding the use or disclosure of Personal Information in compliance with the principles of this privacy policy, you should contact us first at compliance@djeholdings.com and we will contact you promptly to attempt to resolve your concerns or complaint. If contacting us does not resolve your concern or complaint, you may raise your complaint with the relevant DPA where you live or work (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm for contact information). As further explained in the Privacy Shield Framework Annex I, a binding arbitration option is available in the event that residual complaints are not resolved by any other means.

Notification of Changes

As we provide more services and/or functionality on our Site and as privacy laws and regulations evolve, it may be necessary to revise or update our Privacy Policy. We will put an “Updated” note on the link to the Privacy Policy on the Site’s home page so that you will be able to check regarding changes which may be of particular relevance to you.

Accessing and updating your information; Limiting or Opting out

Visitors who would like to access, correct, update or delete any personally identifiable information may contact us with a request to do so at general@morrismclane.com. Similarly, Site users who wish to subscribe or unsubscribe to our marketing and informational communications or limit our use of any personally identifiable information in any way can do so by using the subscribe/unsubscribe options contained in our emails or by sending an email to compliance@djeholdings.com. We may take a reasonable period of time to respond to any request to update or modify any information, limit use of information or to opt out of or unsubscribe from any communications. We may also ask for additional information to authenticate the request. If you request the deletion, modification or limitation of use of your personal information maintained by us we will promptly review your request and respond. If we grant your request, such information may be retained for a period of time in our backup systems as a precaution against system failures. Some information may be retained for longer periods as required by law, contract or auditing requirements. In some circumstances we will not be able to limit use of your personal information without unsubscribing you from communications or deleting your information.

Members of the Media, Social Media Influencers/Users, Subject Matter Experts, Stakeholders

The Company maintains lists of publicly available information regarding media contacts, journalists, social media influencers, social media users, subject matter experts and other stakeholders and individuals who make their personal and/or professional information and/or opinions publicly available. These lists are accessed and/or used by the Company for specific business purposes in conducting its own business and in conducting business on behalf of potential and existing clients. The Company takes reasonable measures to limit the information processed to be relevant to legitimate business purposes and to minimize any risks to individuals associated with the use of such information. Any individual may contact us to access, update and/or restrict use of such information consistent with applicable law by contacting us at  general@morrismclane.com.