Effective November 15^th, 2019

Elite Discovery, Inc. (“we,” “us,” “our”) understands that privacy is important to all its clients and potential clients and that you consider carefully how your Personal Data is used and shared. We respect and value the privacy of everyone who interacts with us and will only collect and use Personal Data in ways that are described here, and in a manner that is consistent with our obligations and your rights at law.

This privacy policy is intended to cover the combined operations and web presence of Elite Discovery, Inc. (Elite).

Data collected in everyday business

As an Electronic Discovery (eDiscovery) platform provider, much of the data we collect, and store is provided and used by clients rather than directly from individuals. Any data received on behalf of clients is used strictly for the business purposes defined in the agreement between the client and Elite. It is not shared with third parties unless otherwise agreed upon.

An individual who seeks access or who seeks to correct, amend, or delete inaccurate data provided to Elite by a client should direct their query to that client. An individual wishing to limit the use or sharing of their data should direct their query to that client.

Internal Staff Information

We will collect personal information about Staff for various purposes, primarily relating to establishing and managing the employment or other work relationship between Elite and its human resources. All Elite staff should refer to our company policy for internal data handling, the policy is made available to all staff during induction and throughout employment with Elite via our shared document repository.

Elite Domains Web Visitors

We gather general information about the use of our websites, such as which areas users visit most frequently, and which services users access the most. We use only aggregated data which cannot identify an individual visitor to our site. This information helps us determine what is most beneficial for our users and how we can continually create a better overall online experience. We may use this general information and share it with our business partners so that they too may understand how this site is used.

How We Use Your Personal Information

By “personal information” we mean any information that may be used to identify you, including, but not limited to your first and last name, physical address, email address or other contact information.

The information collected helps to understand your needs and interests and helps Elite deliver a consistent and personalized experience. For example, Elite may use your information to:

• communicate with you about products and services;
• provide service and support;
• update you on new services and benefits;
• provide personalized promotional offers;
• select content to be communicated to you;
• send you a newsletter, blog information and event details;
• contact you for market research regarding Elite services, or
• for other purposes disclosed to you at the time we collect your information, or pursuant to your consent.

We will give you the opportunity to choose your privacy preferences regarding the communications we send.

If you choose to submit your resume/CV, we will collect personal information about you, such as your name, location and email address. If you supply a resume/CV, then you may also choose to provide us with details of your career history and other personal information such as address, telephone number, gender and nationality.

Information Retention & Disclosure

We will not disclose the personal information that you provide, or details of your individual visits to this website, to any outside However, as described above, we may record general information about the use of our website and share it with our business partners. If this practice should change in the future, we will update this policy and provide individuals with opt-out choice prior to sharing their data with non-agent third parties.

Security

We are committed to protecting the security of all information we receive, yours included. We use a variety of measures to ensure that your personal information is protected from:

• Unauthorized access
• Improper use or disclosure -Unauthorized modification or alteration -Unlawful destruction or accidental loss

All our employees and agents who have access to or are involved in the processing of personal information respect the confidentiality of personal information.

The Internet, nevertheless, is an open system. While we use industry-standard efforts and security practices to safeguard your personal information, we cannot warrant the security of any personal information you elect to provide to us.

You should also be aware that our website may include links to external websites operated by other organizations. They may, like us, collect personal information from visitors to their site. We cannot guarantee the content or privacy practices of any external websites and do not accept responsibility for those websites.

Changes to This Privacy Policy

If we decide to change our privacy commitment, we will post those changes here so that you will always know what information we gather, how we might use that information and whether we will disclose it to anyone.

Consent

By submitting your personal information, you consent to the use of your information as set out in this privacy policy.

ADHERENCE TO EU-US and SWISS-US PRIVACY SHIELD

Elite Discovery, Inc. complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom, and Switzerland transferred to the United States pursuant to Privacy Shield. Elite Discovery, Inc. has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Elite Discovery, Inc. is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data provided to Elite by a client should direct their query to that client.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. An individual wishing to limit the use or sharing of their data should direct their query to that client.

We do not provide information that is provided on our site or anywhere else to any third parties. Information collected is for internal use only.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Elite Discovery, Inc’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. If we were to disclose your personal data to third parties other than our agent, In particular, Elite Discovery, Inc. remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Elite Discovery, Inc. proves that it is not responsible for the event giving rise to the damage.

In compliance with the EU-US and Swiss-U.S. Privacy Shield Principles, Elite commits to resolve complaints about your privacy and our collection or use of your personal information. European or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Elite using the contact information in the questions and contact section below.

Elite Discovery, Inc has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your complaint involves human resources data transferred to the United States from the EU and/or Switzerland in the context of the employment relationship, and Elite Discovery, Inc does not address it satisfactorily, Elite Discovery, Inc commits to cooperate with the panel established by the EU data protection authorities (DPA Panel) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable, and to comply with the advice given by the DPA panel and/or Commissioner, as applicable, with regard to such human resources data. To pursue an unresolved human resources complaint, you should contact the state or national data protection or labor authority in the appropriate jurisdiction. Contact details for the EU data protection authorities can be found at https://edpb.europa.eu/about-edpb/board/members_en. Complaints related to human resources data should not be addressed to the BBB EU PRIVACY SHIELD.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

QUESTIONS and CONTACT INFORMATION

If you have any questions about how your personal information is used, or if you want to access, correct or remove your personal information, please contact our Privacy Management Dept. via email at privacy@elitediscovery.com.

You may write to us at: Elite Discovery, Inc., Attn: Privacy Management Dept, 400 N Saint Paul St., Suite 1300, Dallas, Texas 75201.

Please note that if your complaint is not resolved through these above channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. Additional information is available here: www.privacyshield.gov/article?id=How-toSubmit-a-Complaint