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). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “U.S.-Swiss Safe Harbor”). Consistent with its commitment to protect personal privacy, Morrison Corporate Travel adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.
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Definitions For purposes of this Policy, the following definitions shall apply: “Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Morrison Corporate Travel or to which Morrison Corporate Travel discloses personal information for use on Morrison Corporate Travel’s behalf. “Morrison Corporate Travel” means Morrison Corporate Travel, its affiliates under common control, predecessors, successors, subsidiaries, divisions and groups in the United States. “Personal information” means any information or set of information that identifies or could be used by or on behalf of Morrison Corporate Travel to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with nonpublic personal information.
Privacy Principles The privacy principles in this Policy have been developed based on the Safe Harbor Principles. NOTICE: Where Morrison Corporate Travel 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 Morrison Corporate Travel discloses that information, the choices and means, if any, Morrison Corporate Travel offers individuals for limiting the use and disclosure of personal information about them, and how to contact Morrison Corporate Travel. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Morrison Corporate Travel, or as soon as practicable thereafter, and in any event before Morrison Corporate Travel uses or discloses the information for a purpose other than that for which it was originally collected. Where Morrison Corporate Travel 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.
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Options: Morrison Corporate Travel will offer individuals the opportunity to choose (opt- out) whether their personal information is (a) to be disclosed to a non-agent third
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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, Morrison Corporate Travel 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. Morrison Corporate Travel will provide individuals with reasonable mechanisms to exercise their choices. Individuals may log into their account here to update their contact preferences.
Integrity of Data: Morrison Corporate Travel will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Morrison Corporate Travel will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. Morrison Corporate Travel will retain individual’s personal information for as long as the account is active or as needed to provide services. Morrison Corporate Travel will retain and use personal information as necessary to comply with legal obligations, resolve disputes, and enforce agreements.
Transfer to Agents: Morrison Corporate Travel will transfer personal information (but not sensitive personal information) to agents that provide travel services that an individual (or someone authorized on behalf of such individual) requests. Morrison Corporate Travel does not control the travel suppliers’ use of such information. For other agents, Morrison Corporate Travel 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), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where Morrison Corporate Travel has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Morrison Corporate Travel will take reasonable steps to prevent or stop the use or disclosure.
Morrison Corporate Travel may also transfer personal information as required by law, investigate fraud, or respond to a government request. Morrison Corporate
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Travel may transfer personal information if it merges with or is acquired by a third party, or goes bankrupt and will post a notice on this site regarding choices individuals have with respect to their personal information. Access and correction: Upon request, Morrison Corporate Travel will grant individuals reasonable access to personal information that it holds about them. In addition, Morrison Corporate Travel will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Morrison Corporate Travel will respond to individuals’ request to access within 3 business days.
Security: Morrison Corporate Travel will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, Morrison Corporate Travel cannot guarantee its absolute security.
Enforcement: Morrison Corporate Travel will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Morrison Corporate Travel determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
Dispute Resolution: Any questions or concerns regarding the use or disclosure of personal information should be directed to Morrison Corporate Travel at the address given below. Morrison Corporate Travel will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between Morrison Corporate Travel and the complainant, Morrison Corporate Travel has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles: 1. for disputes involving all personal information received by Morrison Corporate Travel from Switzerland, Morrison Corporate Travel has agreed and to cooperate with the Swiss FDPIC; 2. for disputes involving employment-related personal information received by Morrison Corporate Travel from the EEA, Morrison Corporate Travel has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;
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3. for disputes involving unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at: https://feedbackform.truste.com/watchdog/request.
Morrison Corporate Travel 800 Airport, Suite 410 Burlingame, CA 94010
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