KEEPING YOUR

East West Connection Inc., a privately owned corporation, complies with the EU–U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss–U.S. DPF) set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data (as defined below) from European Union member countries and Switzerland. East West Connection has certified that it adheres to the Data Privacy Framework (DPF) of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; Recourse, Enforcement, and Liability. If there is any conflict between the policies of East West Connection, Inc. and the Data Privacy Framework Policies and Data Privacy Framework Principles, the Data Privacy Framework Principles govern. To learn more about the Data Privacy Framework (DPF) EU-U.S. and the Swiss-U.S. Data Privacy Framework (DPF) Framework program and to view our certification page, please visit https://www.dataprivacyframework.gov/s/.

Definitions

“Data Subject” means the individual to whom any given Personal Data covered by this Data Privacy Framework (DPF) Policy refers.

“Personal Data” means any information relating to an
individual residing in the European Union and Switzerland that can be used to
identify that individual either on its own or in combination with other readily
available data.

“Sensitive Personal Data” means Personal Data regarding an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, or sexual life.

Scope and Responsibility 

This Data Privacy Framework (DPF) Policy applies to Personal Data transferred from European Union member countries and Switzerland to East West Connection’s operations in the U.S. in reliance on the respective Data Privacy Framework (DPF) and does not apply to Personal Data transferred under Standard Contractual Clauses or any approved derogation from the EU Directive.

• To inform transparently about our data processing (Notice Principle),
• To offer individuals the opportunity to choose (opt-out) whether personal information is disclosed to a third party or used for a purpose that is different from the purpose(s) for which it was originally collected (Choice Principle),
• Accept responsibility for onward transfers (Accountability for onward Transfer Principle),
• Ensure data security (security principle),
• Processing only relevant data (Data Integrity and Purpose Limitation Principle),
• Grant data subject rights (Access Principle) and
• Enable effective legal protection (Recourse, Enforcement, and Liability Principle).

Some types of Personal Data may be subject to other privacy-related requirements and policies. For example:

Some East West Connection websites have their own privacy policies.

Personal Data regarding and/or received from a client is also subject to any specific agreement with, or notice to, the client, as well as additional applicable laws and professional standards.

Employee Personal Information is subject to internal human resource policies, including the Employee Data Privacy Notice.

All employees of East West Connection who have access in the U.S. and International countries to Personal Data covered by this Data Privacy Framework Policy are responsible for conducting themselves in accordance with this DPF Policy. Adherence by East West Connection to this DPF Policy may be limited to the extent required to meet legal, regulatory, governmental, or national security obligations, but Personal Data covered by this DPF Policy shall not be collected, used, or disclosed in a manner contrary to this policy without the prior written permission of East West Connection’s Vice President Compliance.

East West Connection employees are responsible for engaging third parties to which Personal Data covered by this Data Privacy Framework Policy will be transferred. They are responsible for obtaining appropriate assurances that such third parties have an obligation to conduct themselves in accordance with the applicable provisions of this Data Privacy Framework (DPF) Principles, including any applicable contractual assurances required by the Data Privacy Framework (DPF).

EU – U.S. and the Swiss-U.S. Data Privacy Framework Principles

East West Connection commits to subject to the Data Privacy Framework (DPF) Principles all Personal Data received by East West Connection in the U.S. from European Union member countries and Switzerland in reliance on the respective Data Privacy Framework (DPF).

1. Notice

East West Connection notifies Data Subjects covered by this Data Privacy Framework (DPF) Policy about its data practices regarding Personal Data received by East West Connection in the U.S. from European Union member countries and Switzerland in reliance on the respective Data Privacy Framework, including the types of Personal Data it collects about them, the purposes for which it collects and uses such Personal Data, the types of third parties to which it discloses such Personal Data and the purposes for which it does so, the rights of Data Subjects to access their Personal Data, the choices and means that East West Connection offers for limiting its use and disclosure of such Personal Data, how East West Connection’s obligations under the Privacy Shield are enforced, and how Data Subjects can contact East West Connection with any inquiries or complaints.

2. Choice

East West Connection discloses personal information only to third parties who are providing goods and/or services, like hotels, transportation companies, etc.. We collect information for specified, explicit, and legitimate purpose/s and do not process the information in a matter that is incompatible with those purpose/s. We share data to the minimum extent necessary.

If Personal Data covered by this Data Privacy Framework Policy is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized or is to be disclosed to a non-agent third party, East West Connection will provide Data Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to info@eastwestconnection.com

If Sensitive Personal Data covered by this Data Privacy Framework (DPF) Policy is to be used for a new purpose that is different from that for which the Personal Data was originally collected or subsequently authorized or is to be disclosed to a third party, East West Connection will obtain the Data Subject’s explicit consent prior to such use or disclosure.

3. Accountability for Onward Transfer

In the event we transfer Personal Data covered by this Data Privacy Framework (DPF) Policy to a third party acting as a controller, we will do so consistent with any notice provided to Data Subjects and any consent they have given, and only if the third party has given us contractual assurances that it will (i) process the Personal Data for limited and specified purposes consistent with any consent provided by the Data Subjects, (ii) provide at least the same level of protection as is required by the Data Privacy Framework (DPF) Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the Personal Data or take other reasonable and appropriate steps to remediate if it makes such a determination. If East West Connection has knowledge that a third party acting as a controller is processing Personal Data covered by this Data Privacy Framework (DPF) Policy in a way that is contrary to the Data Privacy Framework (DPF) Principles, East West Connection will take reasonable steps to prevent or stop such processing.

With respect to our agents, we will transfer only the Personal Data covered by this Data Privacy Framework (DPF) Policy needed for an agent to deliver to East West Connection the requested product or service. Furthermore, we will (i) permit the agent to process such Personal Data only for limited and specified purposes; (ii) require the agent to provide at least the same level of privacy protection as is required by the Data Privacy Framework (DPF); (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the Personal Data transferred in a manner consistent with East West Connection’s obligations under the Data Privacy Framework (DPF) Principles; and (iv) require the agent to notify East West Connection if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Data Privacy Framework (DPF) Principles. Upon receiving notice from an agent that it can no longer meet its obligation to provide the same level of protection as is required by the Data Privacy Framework (DPF) Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.

East West Connection remains liable under the Data Privacy Framework (DPF) Principles if an agent processes Personal Data covered by this Data Privacy Framework (DPF) Policy in a manner inconsistent with the principles, except where East West Connection is not responsible for the event giving rise to the damage.

4. Security

East West Connection takes reasonable and appropriate measures to protect Personal Data covered by this Data Privacy Framework (DPF) Policy 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 Data.

5. Data Integrity and Purpose Limitation

East West Connection limits the collection of Personal Data covered by this Data Privacy Framework (DPF) Policy to information that is relevant for the purposes of processing. East West Connection does not process such Personal Data in a way incompatible with the purposes for which it has been collected or subsequently authorized by the Data Subject.

East West Connection takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. East West Connection takes reasonable and appropriate measures to comply with the requirement under the Data Privacy Framework (DPF) to retain Personal Data in identifiable form only for as long as it serves a purpose of processing, which includes East West Connection’s obligations to comply with professional standards, East West Connection’s business purposes and unless a longer retention period is permitted by law, and it adheres to the Data Privacy Framework (DPF) Principles for as long as it retains such Personal Data.

6. Access

Data Subjects whose Personal Data is covered by this Data Privacy Framework (DPF) Policy have the right to access such Personal Data and to correct, amend, or delete such Personal Data if it is inaccurate or has been processed in violation of the Data Privacy Framework (DPF) Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). Requests for access, correction, amendment, or deletion should be sent to info@eastwestconnection.com

7. Recourse, Enforcement, and Liability

East West Connection’s participation in the EU-U.S. and the Swiss-U.S. Data Privacy Framework (DPF) Framework is subject to investigation and enforcement by the U.S. Federal Trade Commission.

In compliance with the EU-U.S. and the Swiss-U.S. Data Privacy Framework (DPF) Principles, East West Connection commits to resolving complaints about your privacy and our collection or use of your Personal Data. Data Subjects with inquiries or complaints regarding this Data Privacy Framework Policy should first contact East West Connection at info@eastwestconnection.com

East West Connection has further committed to refer unresolved privacy complaints under the EU-U.S. and the Swiss-U.S. Data Privacy Framework (DPF) Data Privacy Framework (DPF) to an independent dispute resolution mechanism, Privacy Trust. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.privacytrust.com/about/contact.php for more information and to file a complaint.

Under certain conditions detailed in the EU-U.S. and the Swiss-U.S. Data Privacy Framework (DPF) Subjects may invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.

East West Connection agrees to periodically review and verify its compliance with the Data Privacy Framework (DPF) Principles and to remedy any issues arising out of failure to comply with the Data Privacy Framework (DPF) Principles. East West Connection acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of Privacy Shield participants.

Changes to this EU-U.S. and the Swiss-U.S. Data Privacy Framework (DPF) Framework

This EU-U.S. and the Swiss-U.S. Data Privacy Framework (DPF) Framework Policy may be amended from time to time, consistent with the requirements of the Data Privacy Framework (DPF). Appropriate notice regarding such amendments will be given.