Privacy Policy

Introduction

Morae Global Corporation and each of its subsidiaries (“Morae,” “we,” “us,” or “our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (the “Policy”).

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, Phoenix Business Solutions (US), Ltd, and Morae Australia Pty Ltd.

This Policy describes Morae’s practices for collecting, storing, using, maintaining, protecting and disclosing information Morae collects from you, including the information Morae collects from you when you visit the website www.moraeglobal.com (“Website”). This Policy does not cover third party sites that Morae links to. By communicating with Morae or accessing or using the Website, you agree to the terms of this Policy, which is incorporated into our Terms of Use. If you do not agree to the terms of this Policy, please do not communicate with Morae or use the Website.

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
• AAs 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.

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.

Cross-border transfers

Morae may use third parties located in other countries to help us run our business. As a result, Personal Information may be transferred outside the countries where we and our clients are located.

This includes transfers to countries outside the European Economic Area (“EEA”) and to countries that may not have laws that provide the same degree of protection for personal information as your home country. In accordance with applicable legal requirements, we take appropriate measures to facilitate adequate protection for any information so transferred.

Where we transfer personal information outside of the EEA to a country or framework not determined by the European Commission as providing an adequate level of protection for personal information, the transfers will be under an agreement which covers European Union requirements for such transfers, such as standard contractual clauses.

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 fulfil 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.

Third-Party Websites

The Website may contain links to third-party websites that are beyond Morae’s control. If you choose to access such websites, Morae is not responsible for any actions or policies of such third parties. Morae recommends that you review the applicable privacy policy of such third party before submitting any information to them.

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: privacy@moraeglobal.com. We will process your opt-out request as soon as possible and in accordance with applicable law.

Privacy Rights

California – 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.

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.

European Economic Area, Switzerland and United Kingdom – If you are an individual located in the European Economic Area, in certain circumstances under applicable law (specifically in connection with certain services that we provide), you may have the right to access or obtain a copy of your personal information, to rectify your personal information, to have your personal information deleted, to restrict the processing of your personal information, to object to the processing of your personal information, to data portability, and to withdraw your consent for processing (where processing is based on your consent). Please note that if you withdraw your consent, we may not be able to provide you the services for which it was necessary to process your information based on your consent.

Australia – We adhere to the privacy requirements covered by the Australian Privacy Act 1988 (Cth) (“Privacy Act”) and you always have the opportunity to query our use of your Personal Information.

To exercise any of these rights, please send an email to privacy@moraeglobal.com.

New Trans-Atlantic Data Privacy Framework

The judgment in the Schrems II case issued by the European Court of Justice in 2020 found that Privacy Shield framework no longer provides adequate safeguards for the transfer of personal data to the United States from the EEA.

The United States (“U.S.”) and the European Commission (“EU Commission”) announced in 2022 an “agreement in principle” to develop a new Trans-Atlantic Data Privacy Framework (“Framework”). The Framework is intended to re-establish a legal mechanism for transfers of EU personal data to the U.S. after the Court of Justice of the European Union (“CJEU”) invalidated the EU-U.S. Privacy Shield.

In the interim, 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 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.

Changes to the Privacy Policy

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.

Contact Information

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
privacy@moraeglobal.com

Complaints

United Kingdom

You have the right to complain to the Information Commissioner’s Office (“ICO”) in the UK (as the UK’s data protection regulator) at https://ico.org.uk.

Australia
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.

Cookies and Similar Technologies

Morae may use cookies and other similar technologies to provide our services and to help collect data. We explain in more detail below:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, Morae’s system will issue cookies when you direct your browser to the Website.
• 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).