HIREBRIDGE EU-US PRIVACY SHIELD POLICY

Hirebridge, LLC (“Hirebridge”, “we”, “our” or “us”) 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 from European Union member countries. Hirebridge has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. Privacy Shield program, and to view Hirebridge’s certification, please visit privacyshield.gov.

Hirebridge is committed to protecting the privacy of your Personal Information (as defined below). We respect individual privacy and value the trust of our customers and employees, consumers, patients, health care providers, business partners and others who provide their Personal Information to us. This EU-U.S. Privacy Shield Policy (the “Policy”) sets forth the privacy principles that Hirebridge follows with respect to transfers of personal information from the European Union to the United States, and is intended to give you confidence in the privacy and security of your Personal Information when accessing the available pages on any of the following Hirebridge websites (collectively, the “Site”):

The Site provides you with information about Hirebridge and our services and products. Hirebridge collects data to operate effectively and provide you the best experiences with our services and products.

COMPLIANCE WITH PRIVACY SHIELD PRINCIPLES

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the “EU-U.S. Privacy Shield Framework”) to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the U.S.

We recognize that the European Community has established a data protection regime which applies to the European Economic Area (“EEA”) and restricts companies in the EEA in transferring personal data about individuals in the EEA to the U.S., unless there is “adequate protection” for such personal data when it is received in the U.S. To create such “adequate protection,” Hirebridge adheres to the EU-U.S. Privacy Shield Framework published by US Department of Commerce (“EU-U.S. Privacy Shield Principles”) with respect to personal data about individuals in the EEA that we receive from our customers and other business partners. Hirebridge’s EU-U.S. Privacy Shield Certification also extends to data that we receive directly through Hirebridge’s publicly accessible Site via secure form submission.

ADHERENCE TO SEVEN PRIVACY SHIELD PRINCIPLES

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

NOTICE: Where Hirebridge collects Personal Information (as defined below) directly from individuals in the EEA, we will inform them about the purposes for which we collect and use personal information about them, the types of non-agent third parties to which we disclose that information, the choices and means, if any, we offer individuals for limiting the use and disclosure of personal information about them, and how to contact us. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Hirebridge, or as soon as practicable thereafter, and in any event before Hirebridge uses or discloses the information for a purpose other than that for which it was originally collected.

Where Hirebridge receives Personal Information from 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. “Personal Information” means any information or set of information that identifies or could be used to identify you. Personal Information collected by the Site may include name, address, contact numbers, e-mail address, but may include other information when needed (for example, to provide a requested service, where an employment opportunity is being processed or where a health professional is interested in participating in a clinical trial). Personal Information does not include information that is anonymized such that an individual cannot be identified.

CHOICE: You may elect not to have your Personal Information either (a) disclosed to an unrelated third party, or (b) used for a purpose other than the purpose for which it was originally collected or subsequently authorized by you. In the event you wish to restrict your Personal Information from any such disclosure or use, please contact us at privacy@hirebridge.com to review your request. You may have an opportunity to elect to receive recurring informational/promotional e-mail from us. Our email correspondence will include instructions on how to update certain Personal Information and how to unsubscribe from our emails. Please follow the instructions in the emails to opt-out of an email. We will unsubscribe you from that newsletter or other programs within thirty business days.

ACCOUNTABILITY FOR ONWARD TRANSFERS TO THIRD PARTIES: Hirebridge is responsible for Personal Information in our possession or custody, including Personal Information that we may transfer to third parties for processing, including storage. In connection with the purposes described in the “Notice” Section above, Hirebridge may transfer your Personal Information to other companies within the Hirebridge group of companies or to third parties such as external service providers. In cases of onward transfers to third parties, Hirebridge will limit the Personal Information shared to the minimum amount necessary, and will obtain assurances from third party business partners (agents) that they will safeguard Personal Information consistent with this Policy. Examples of appropriate assurances that may be provided by third party business partners include: a contract obligating the third party to provide at least the same level of protection as is required by the applicable laws and regulations, including the EU Directive 95/46/EC (the EU Data Protection Directive), standard contractual clauses as approved by the European Commission, certification under the EU-U.S. Privacy Shield, or being subject to another European Commission adequacy finding. Where Hirebridge has knowledge that a third party business partner is using or disclosing personal information in a manner contrary to the company policy, Hirebridge will take reasonable steps to prevent or stop the use or disclosure. Hirebridge remains responsible and liable under the EU-U.S. Privacy Shield Principles if a third-party business partner uses or discloses Personal Information in a manner inconsistent with the EU-U.S. Privacy Shield Principles, unless Hirebridge proves that we are not responsible for the event giving rise to the damage.

SECURITY: Hirebridge will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

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

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

VERIFICATION: Hirebridge will use a self-assessment verification approach and conduct compliance audits of its applicable privacy practices to verify adherence to this Policy.

DISPUTE RESOLUTION AND ENFORCEMENT: In compliance with the EU-U.S. Privacy Shield Principles, Hirebridge commits to resolve complaints about your privacy and our collection or use of your Personal Information. EU individuals with inquiries or complaints regarding this Policy should first contact Hirebridge by sending the inquiry or complaint to the address listed below or to: privacy@hirebridge.com.

Hirebridge will respond within 45 days of receiving any complaints. Any complaints or concerns that cannot be resolved internally will be referred to JAMS Privacy Shield Program, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgement of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS Privacy Shield Program are provided at no cost to you.

Under certain circumstances, an individual may choose to invoke binding arbitration to resolve any disputes that have not been resolved by other means.

Hirebridge complies with the EU-U.S. Privacy Shield Principles and is subject to the investigatory and enforcement powers of the FTC.

Any employee that Hirebridge determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

LIMITATION ON APPLICATION OF PRINCIPLES: Adherence by Hirebridge to these EU-U.S. Privacy Shield Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet legal, governmental or national security obligations, including requirements to cooperate with law enforcement; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

CHANGES TO THIS PRIVACY SHIELD PRIVACY POLICY: This Policy may be amended from time to time, consistent with the requirements of the EU-U.S. Privacy Shield Principles. When material updates are made, the date of the last revision will be reflected at the end of the page.

CONTACT INFORMATION: Questions or comments regarding this Policy should be submitted to Hirebridge’s Privacy Office by mail to:

Hirebridge,LLC
Attn: Privacy Officer
3200 N. University Dr. Suite 214
Coral Springs, FL 33065

or by e-mail to Hirebridge’s Privacy Office: privacy@hirebridge.com

EU-U.S. PRIVACY SHIELD POLICY EFFECTIVE DATE: January 2017



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