Privacy Policy

Modernizing Processes is committed to meeting legal and regulatory requirements regarding data protection and privacy where it conducts its business activities. This Privacy Policy (“Policy”) defines the minimum standards with respect to Modernizing Processes collecting, processing, or otherwise using personal data, including information that may be considered as sensitive Personal Data (“Personal Data”) about individuals including our associates, business contacts, customers, or vendors (“Individuals”).

Privacy Principles

Modernizing Processes will handle Personal Data in accordance with the following principles. Modernizing Processes ensures that its business partners and vendors comply with the principles of this Policy and applicable legal and regulatory compliance standards through appropriate contractual agreements.

Lawfulness of Processing

Modernizing Processes will collect, store, process, use, share, transfer, analyze, or otherwise handle (“Process” or “Processing”) Personal Data in accordance with applicable legal requirements for legitimate business or compliance purposes, or if individuals have provided consent to the Processing or any relevant basis as defined by the applicable laws or regulations.

Limit Collection and Processing

Modernizing Processes will limit the Processing of Personal Data in terms of scope and duration, as is necessary for the intended purpose.

Transparency

In accordance with applicable legal requirements, Modernizing Processes will provide information to individuals that explains the scope and purpose of Processing, and whom to contact to seek clarifications about privacy or data protection.

Accuracy

Modernizing Processes will take all necessary measures, as required by applicable laws and regulations, to ensure that Personal Data processed are accurate for the intended purpose. Any inaccurate personal data, in the context of the purposes for which they are processed, will either be erased or rectified without delay. Accuracy of data may be subject to the data subject’s duty to notify and/or utilize the options as outlined in Privacy Notices.

Security and Confidentiality

Modernizing Processes aims to protect the security and confidentiality of individuals’ Personal Data and implements physical, technical, and organizational measures against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access. Modernizing Processes will ensure measures are appropriate to the risks represented by the Processing it carries out and the nature of those Personal Data.

Privacy by Design

Modernizing Processes incorporates the principles of Privacy by Design into all of its personal data processes executed using digital systems, technologies, or manually. By default, privacy requirements are embedded into every standard, protocol, and process followed by Modernizing Processes.

Disclosure

Modernizing Processes discloses, when required/asked, personal data to third parties only for the purposes identified in the privacy notice, with the consent of the individual, or as required for lawful purposes. Third parties refer to public authorities, Law Enforcement Agencies, and similar authorities.

Data Subject Rights

In accordance with applicable legal requirements, Modernizing Processes will provide opportunities to exercise data subject rights, which are available to the individuals in the context of their engagement with Modernizing Processes. Such rights may include the right to request access to their Personal Data, to correct inaccurate or incomplete Personal Data, or to object to the Processing of their Personal Data. Each Data Subject Request is validated and tracked to closure. As per the applicable law, and the engagement of data subjects with Modernizing Processes, there might be other rights available such as the right to be forgotten, the right to withdraw consent, the right to data portability, etc. Modernizing Processes will ensure its compliance and deploy all required measures to help data subjects exercise their rights granted.

International Data Transfers

Modernizing Processes operates on a global level and from time to time it may be required to transfer Personal Data across countries. Modernizing Processes recognizes that Personal Data needs to be treated with care, including data transfer to countries, which may not have adequate data protection laws. If Modernizing Processes transfers Personal Data to such countries, it will protect these Personal Data as set out in this Policy and in accordance with the requirements of applicable law.

Data Retention

Modernizing Processes will observe retention policies and procedures so that it deletes Personal Data after a reasonable time and the purposes are met. An exception applies if in the context of those purposes, it is necessary to keep the Personal Data indefinitely, or a law requires the Personal Data to be kept for a certain time. When Modernizing Processes no longer needs to keep Personal Data for the purposes, for which they are held, it will delete them as soon as practicable.

Jurisdiction-Specific Requirements and Implementation

National data protection and privacy laws may impose additional requirements on Modernizing Processes for the Processing of Personal Data. Where required, Modernizing Processes will establish procedures and guidelines in order to supplement the principles of this Policy and engage with relevant regulatory/supervisory authorities, as required.

Privacy Organization and Contact

Modernizing Processes has set up a global Privacy Function, which is headed by the Head – Global Privacy Office of Modernizing Processes, and which is tasked with overseeing and implementing privacy and applicable data protection requirements. Specific data protection or privacy functions and roles may be added for individual countries or geographies. Modernizing Processes also appoints Data Protection Officers (or comparable function), where required by applicable laws. The privacy function is also responsible for deploying training and awareness programs and supporting the implementation of privacy principles into Modernizing Processes’ business operations and processes. If you have questions about this Policy, please direct them to the contact details provided in the privacy notice available at www.modernizingprocesses.com.

Data Breach Reporting

All known or suspected incidents involving Personal Data must be reported immediately upon discovery. This includes incidents notified to Modernizing Processes by any associate, client, third-party service provider, or other business partner. Modernizing Processes will provide education and awareness to its workforce regarding the procedures for reporting a suspected or confirmed incident. Each incident is investigated and tracked to closure. If the investigation leads to the conclusion that an illegal, improper, or unethical act has been committed, appropriate disciplinary or corrective action will be initiated against the offender as per Modernizing Processes’ policy and legal provisions.

Implementation

Modernizing Processes has internal arrangements in place to communicate, ensure, and verify compliance with this Policy, to protect data, allow effective exercise of individuals’ rights set out in this Policy and under applicable law, and to deal with any concerns from individuals or regulatory bodies that Modernizing Processes may not have complied with the Policy and/or applicable law. All individuals can leverage these arrangements and/or exercise their rights by contacting their local Data Protection Officer.

Changes to the Policy

Modernizing Processes may update this Policy from time to time and without prior notice to individuals to reflect changes in law or privacy practices. If you have questions about this Policy, please direct them to the Head – Global Privacy Office or to the respective local Data Protection Officer, whose contact details can be referred to in the privacy notice available at www.modernizingprocesses.com.