Privacy Statement

Overview

Personal Data is information that can be used directly or indirectly to identify a living individual. Personal Data may include sensitive categories of information, such as information that reveals racial or ethnic origin, political opinions, religious beliefs, trade union membership, health or sexual orientation (Sensitive Personal Data).

This policy applies to Moriarty and Associates Consulting Corporation (MAC), and is effective as of December 1, 2008. All employees will be required to abide by this policy.

MAC realizes that this policy cannot address every potential issue and circumstance. Therefore, we acknowledge that this policy is subject in all respects to applicable local legal and regulatory requirements and existing agreements, and confirm that we will comply with such requirements and existing agreements.

Privacy Principles

We will observe the privacy principles described below of Notice, Choice/Fair Processing, Access, Security/Integrity, Onward Transfer and Enforcement/Compliance in processing Personal Data.

Choice/Fair Processing

We will process Personal Data only with consent or when such processing is permitted by applicable law. If we need to process Sensitive Personal Data, we will obtain explicit consent for such processing, unless such processing is permitted by applicable law.

We will not process Personal Data in a manner incompatible with the purposes for which it was originally collected unless later authorized by the affected individual(s) or allowed by law; we will take reasonable steps to ensure that such data is accurate, adequate, relevant and not excessive in relation to such purposes; and we will not keep such data longer than is necessary for such purposes.

We will enable individuals to choose whether their Personal Data can be disclosed to a third party for direct marketing purposes.

Access

We will allow individuals reasonable access to their Personal Data to verify, correct or delete their data where inaccurate. We will also provide a means for individuals to exercise all other legal rights that they may have in relation to their Personal Data.

Personal Data will be accessible and processed only by MAC employees, suppliers, business partners and others who require access for the performance of their obligations to MAC; any person granted access by the individual to whom Personal Data pertains; and those otherwise authorized by law or court order.

Security/Integrity

We will employ reasonable security procedures through appropriate technical and organizational measures to protect against unauthorized or unlawful access or processing, disclosure, alteration, destruction or accidental loss of Personal Data.

We will utilize reasonable means to keep Personal Data accurate, complete and current in order to protect the quality and integrity of Personal Data; however, we rely on individuals to provide all relevant information and to advise us of any changes to their Personal Data to ensure that it remains accurate, complete and current.

Onward Transfer

When we transfer Personal Data within MAC or to third parties (including our suppliers and business partners), we will observe the privacy principles of Notice and Choice (described above), and we will require all the recipients of such data to provide at least the same level of protection for such data as specified by the standards stated in this policy.

MAC Web Sites

In addition to all other Personal Data handled by MAC, this policy applies to Personal Data collected through MAC Web sites.

As a convenience to our Web site visitors, we sometimes provide links to other Web sites. These linked sites are not under the control of MAC, and, as such, we are not responsible for their content.

Updating the Policy

Changes in legislation and/or our business activities may require that this policy be updated from time to time.

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