Last Updated: December 15, 2020
Subsidiaries of Morae Global Corporation include Morae Services India Private Limited, Clutch Group LLC, Clutch Consulting UK Limited, Clutch Group Switzerland LLC, Phoenix Business Solutions (UK) Limited, Phoenix Business Solutions GmbH, and Phoenix Business Solutions (US), Ltd.
Information Morae Collects from You
Morae collects information from and about individuals in the course of our business activities. “Personal Information” is any information relating to an identified or identifiable natural person. “Non-Personal Information” includes technical information that does not identify an individual personally. Please note that over time Non-Personal Information could become Personal Information through regulatory developments, technological advancements, or co-mingling with Personal Information. We may collect various types of personal information from and about you including:
- Name, postal address, e-mail address, and telephone number;
- Profile information and content that you post on the Website;
- Device information, such as information about your computer and Internet connection, including your operating system, and browser type;
- Usage details, such as details of your visits to the Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website; and
- Cookies and similar technologies. For more information, please see the section addressing cookies below.
Methods Used to Collect Information From and About You
Morae receives personal data directly from individuals in instances where their contact details are shared through the following methods:
- Establishing a business relationship
- As part of a contractually obligated service/product
- Attending an event or meeting (organized by us or through a 3rd party)
- Indicating the preference of receiving further communication from us (e.g. forms, business card, subscriptions and messages)
- Applying for speculative and open vacancies
Morae also receives personal data indirectly from individuals through the following methods:
- Recruitment services from agencies, personal referrals and reference service providers
- Statements of Work for our clients as part of a professional services contract
- Client Record Management systems entries with contact details for individuals
- Public records such as official registers, brochures and internet search returns
- Social and professional networking sites
Mechanisms for Limiting Personal Data Use
We have implemented technical and organizational security policies and procedures to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We ensure that access to your personal data is limited only to those who need to access it for the purposes stated within the related sections.
We ensure that all appropriate confidentiality obligations and technical and organizational security measures are in place to prevent any unauthorized or unlawful disclosure or processing of such information and data and the accidental loss or destruction of or damage to such information and data.
Only authorized individuals have access to the data are they are required to maintain the confidentiality of such information.
Legal Basis for Processing Your Information
We process personal information in accordance with applicable law and with transparency and fairness. Our processing activities are conducted:
- With your consent;
- In order to fulfill our contractual obligations to you;
- For the legitimate purpose of operating our business, including to improve and develop our services, for fraud prevention purposes, and to improve user experience;
- As otherwise in compliance with the law.
How Morae Uses Your Information
Morae uses information that is collected about you or that you provide to Morae, including any Personal Information, to:
- present the Website and its content to you;
- provide you with information, products, or services that Morae may provide to you;
- present aggregated information that does not identify any individual;
- improve services to our clients and interested parties that have shared their contact details and;
- fulfill any other purpose for which you provide the information.
Morae may disclose Personal Information that Morae collects or you provide as described in this Policy to:
- Morae’s subsidiaries and affiliates;
- Contractors, service providers, and other third parties Morae uses to support Morae’s business (and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which Morae discloses it to them); and
- A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Morae’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Morae is among the assets transferred.
We remain responsible and liable under the Privacy Shield Principles if a third party that we engage to process personal information on our behalf does so in a manner inconsistent with the Privacy Shield Principles, unless we verify that we are not responsible for the matter giving rise to the breach.
Morae may also disclose your Personal Information:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- if Morae believes disclosure is necessary or appropriate to protect the rights, property, or safety of Morae, Morae’s customers, or others.
Morae may transfer the Personal Information Morae collects from you to other countries to be processed by Morae and its third-party data processors for the purposes identified in this Policy. By providing information to Morae or otherwise accessing the Website, you consent to the storage, processing and transfer of Personal Information to non- European Economic Area (EEA) countries for these purposes.
When transferring Personal Information outside the EEA, Morae will ensure an adequate level of protection for your rights and freedoms in relation to the processing of your Personal Information.
Security and Retention of Your Information
Morae has implemented technical and organizational security policies and procedures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.
We aim to ensure that access to your personal data is limited only to those authorized to access it. Those individuals and entities with access to the data are required to maintain the confidentiality of such information. Any transmission of Personal Information to Morae is at your own risk. Morae retains your Personal Information for the period necessary to fulfill the purpose for which it was collected, as set forth in this Policy, unless a longer retention period is required or permitted by applicable law.
Opting Out: How You Control the Use of Your Personal Information
If you decide you want to opt out from Morae’s use of your Personal Information, you may do so by notifying Morae by email at: [email protected]. We will process your opt-out request as soon as possible and in accordance with applicable law.
Your California Privacy Rights
If you are a California resident, such as the California Consumer Privacy Act (the “CCPA”) California law may provide you with additional rights regarding our use of your personal information. You will not be discriminated against for exercising your rights under CCPA.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].
Individual Rights of European Union, United Kingdom and Swiss Citizens, as well as those citizens of jurisdictions with comparable data privacy regimes
You have the right to:
- Obtain confirmation as to whether or not your personal information exists and to be informed of its content and source, verify its accuracy and request its correction, completion, update, or amendment;
- Request the deletion, anonymization or restriction of the processing of your personal information processed in breach of the applicable law;
- Object to the processing, in all cases, of your personal information for legitimate reasons;
- Receive an electronic copy of your personal information, if you would like such a copy for yourself or to port your personal information to a different provider;
- Request that your personal information is not sold to third parties (where applicable);
- Lodge a complaint with the relevant data protection supervisory authority.
To exercise any of these rights, please send an email to [email protected], provided that these rights are appliable to your jurisdiction, please send an email to [email protected]. Please note that if you are an Australian citizen you may exercise these rights through the Office of the Australian Information Commissioner (“OAIC”) at https://www.oaic.gov.au/.
Privacy Shield Requirements
Morae recognizes the importance of data protection and embrace a heightened duty to protect personal data that is entrusted to us. Morae is aware that on 16 July 2020, the European Union Court of Justice (“CJEU”) made a judgement to invalidate the EU-US Privacy Shield, which is the legal framework designed to support transatlantic data transfers from the European Union to the US in compliance with EU law. Morae is taking the below outlined steps to ensure that transfers of personal data from the European Union (EU) to the United States (US) can occur in line with EU data protection laws.
Morae will continue to uphold its obligations under the EU-US Privacy Shield framework in order to comply with US law. To ensure that transfers of personal data from the EU to the US can occur in line with European data protection laws, Morae will enter into the Standard Contractual Clauses (sometimes referred to as model clauses) with our vendors who process personal data, and with our customers upon request. These Standard Contractual Clauses legitimize the transfer of personal data from the EU to the US.
Morae continues to closely follow developments to alternative regimes that will allow for continued, unrestricted, data flow between the EU and US, will update its response as announcements and further guidance becomes available from European supervisory authorities.
Morae commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of our employment relationship with you.
Our commitments under the Privacy Shields are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). We may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Under such circumstances, we may be prohibited by law, court order or other legal process from providing notice of disclosure.
In compliance with the Privacy Shield Principles, Morae commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Morae at [email protected]. You may have the option to invoke binding arbitration under the Privacy Shield Principles for the resolution of your complaint under certain conditions. For further information, please see the Privacy Shield website. To learn more about the Privacy Shield, please visit https://www.privacyshield.gov.
Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through Morae’s internal processes, Morae has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/
Morae may change this Policy from time to time. When we do, we will also revise the “Last Updated” date at the top of this Policy. For material changes to this Policy, we will attempt to obtain your consent before implementing the change by sending a notice to the primary email address specified in your account or by placing a prominent notice on the Website. Your continued use of the Website after Morae makes changes is deemed to be acceptance of those changes.
Questions, comments or complaints regarding the Policy may be sent to the postal or email address below:
Morae Global Corporation
1000 Louisiana Street, Suite 6550
Houston, Texas 77002
Cookies and Similar Technologies
- Flash Cookies. Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Morae, for example, to count users who have visited those pages and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).