KEEPING YOUR

East West Connection, Inc. (EWC), a privately owned corporation, complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. EWC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. EWC has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Definitions
“Data Subject” means the individual to whom any given Personal Data covered by this Data Privacy Framework 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 Policy applies to Personal Data transferred from European Union member countries and Switzerland to EWC’s operations in the U.S. in accordance with EWC’s commitment to the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) and to the rights of EU and UK individuals and Swiss individuals and does not apply to Personal Data transferred under Standard Contractual Clauses or any approved derogation from an EU and/or Swiss Directive.

This policy only extends to eastwestconnection.com and to no other subsidiaries or commercial websites.  Some types of Personal Data may be subject to other privacy-related requirements and policies. For example: Some EWC 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.  Personal data will be used by EWC to deliver services in support of contracted meetings and events for its clients. EWC will use Personal Data to manage hotel accommodations, travel arrangements, meal provisions, and other entertainment and activities.

Employee Personal Information is subject to internal human resource policies, including the Employee Data Privacy Notice.  All employees of EWC that have access in the U.S. to Personal Data covered by this Data Privacy Framework Policy are responsible for conducting themselves in accordance with this Data Privacy Framework Policy. Adherence by East West Connection to this Data Privacy Policy may be limited to the extent required to meet legal, regulatory, governmental, or national security obligations, but Personal Data covered by this Data Privacy Framework Policy shall not be collected, used, or disclosed in a manner contrary to this policy without the prior written permission of EWC’s Chief Privacy Officer.

EWC employees responsible for engaging third parties to which Personal Data covered by this Data Privacy Framework Policy will be transferred are responsible for obtaining appropriate assurances that such third parties have an obligation to conduct themselves in accordance with the applicable provisions of the Data Privacy Framework Principles. EWC commits to subject to the Data Privacy Framework Principles all Personal Data received by EWC in the U.S. from European Union member countries and Switzerland in reliance on the respective Data Privacy Framework, i.e., a commitment to the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) and to the rights of EU and UK individuals and Swiss individuals.

1. Notice
   EWC notifies Data Subjects covered by this Data Privacy Framework Policy about its data practices regarding Personal Data received by EWC 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 EWC offers for limiting its use and disclosure of such Personal Data, how EWC’s obligations under the Data Privacy Framework are enforced, and how Data Subjects can contact EWC with any inquiries or complaints.
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2. Choice
   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, EWC 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: privacy@eastwestconnection.com If Sensitive Personal Data covered by this Data Privacy Framework 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, EWC will obtain the Data Subject’s explicit consent prior to such use or disclosure.
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3. Accountability for Onward Transfer
   In the event EWC transfers Personal Data covered by this Data Privacy Framework Policy to a third party acting as a controller, EWC 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 EWC 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 Principles and notify EWC 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 EWC has knowledge that a third party acting as a controller is processing Personal Data covered by this Data Privacy Framework Policy in a way that is contrary to the Data Privacy Framework Principles, EWC will take reasonable steps to prevent or stop such processing.

With respect to EWC’s agents, EWC will transfer only the Personal Data needed for an agent to deliver to EWC the requested product or service. Furthermore, EWC 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 Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the Personal Data transferred in a manner consistent with EWC’s obligations under the Data Privacy Framework Principles; and (iv) require the agent to notify EWC 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 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 Principles, EWC will take reasonable and appropriate steps to stop and remediate unauthorized processing.

Typical third parties that EWC shares data with are destination management companies, hotels, and travel management companies. The data shared is to arrange for travel and accommodation of meeting and event attendees.
EWC remains liable if an agent processes Personal Data covered by this Privacy Policy in a manner inconsistent with the Principles, except where EWC is not responsible for the event giving rise to the damage.

4. Security
   EWC takes reasonable and appropriate measures to protect Personal Data covered by this Data Privacy Framework 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.
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5. Data Integrity and Purpose Limitation
   EWC limits the collection of Personal Data covered by this Data Privacy Framework Policy to information that is relevant for the purposes of processing. EWC does not process such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the Data Subject. Typical information for EWC to store includes, but is not limited to, name, work address, home address, meal preferences, travel schedule. When working with Key Opinion Leaders, data required for reporting based on applicable legal requirements such as expense receipts, passport number and social security number are retained for government mandated reporting. EWC takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. EWC takes reasonable and appropriate measures to comply with the requirement under the Data Privacy Framework Policy  to retain Personal Data in identifiable form only for as long as it serves a purpose of processing, which includes EWC’s obligations to comply with professional standards, EWC’s business purposes and unless a longer retention period is permitted by law, and it adheres to the Data Privacy Framework Principles for as long as it retains such Personal Data.
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6. Access
   Data Subjects whose Personal Data is covered by this Data Privacy Framework 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 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: privacy@eastwestconnection.com.
   Pursuant to applicable laws, EWC will release any requested and relevant information it retains to law enforcement organizations to meet national security or law enforcement requirements after receipt of valid judicial instruction.
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7. Recourse, Enforcement, and Liability
   EWC’s participation in the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework is subject to investigation and enforcement by the Federal Trade Commission.
   In compliance with the Data Privacy Framework Principles, EWC commits to resolve complaints about your privacy and our collection or use of your Personal Data. EU and Swiss individuals with inquiries or complaints regarding this Data Privacy Framework Policy should first contact EWC at: privacy@eastwestconnection.com.
   EWC has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Data Privacy Framework Principles 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://privacytrust.com/services/data-privacy-framework/dispute-resolution for more information and to file a complaint. The services of Privacy Trust are provided at no cost to you.

East West Connection is obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles, provided that an individual has invoked binding arbitration by delivering notice to your organization and following the procedures and subject to conditions set forth in Annex I of Principles.

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

Changes to this Data Privacy Framework Policy: This Data Privacy Framework Policy may be amended from time to time, consistent with the requirements of the U.S. Department of Commerce and the European Commission, UK Government, and Swiss Federal Administration. Appropriate notice regarding such amendments will be given.