European Safe Harbor Privacy Policy

UnitedLex Corporation (“UnitedLex”) strives to collect, use and disclose Personally Identifiable Information (defined below) in a manner consistent with the laws of the countries in which it does business and has a tradition of upholding the highest ethical standards in its business practices. UnitedLex abides by the Safe Harbor Principles developed by the U.S. Department of Commerce and the European Commission and the Frequently Asked Questions (FAQs) issued by the Department of Commerce on July 21, 2000. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles that UnitedLex follows with respect to transfers of Personally Identifiable Information anywhere in the world, including transfers from the European Economic Area (EEA) to the United States.

“Personally Identifiable Information” shall mean any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

The following privacy principles apply solely to the extent that UnitedLex collects Personally Identifiable Information directly from individuals.

Notice
UnitedLex will inform individuals about the purposes for which it collects and uses Personally Identifiable Information about them, the types of non-agent third parties to which UnitedLex discloses that information, and the choices and means, if any, UnitedLex offers individuals for limiting the use and disclosure of their Personally Identifiable Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personally Identifiable Information to UnitedLex, or as soon as practicable thereafter, and in any event before UnitedLex uses the information for a purpose other than that for which it was originally collected.

Choice
UnitedLex will offer individuals the opportunity to choose (opt out of) whether their Personally Identifiable Information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For sensitive Personally Identifiable Information, UnitedLex will give individuals the opportunity to affirmatively and explicitly (opt in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

UnitedLex will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.

In order to request that UnitedLex not use an individual’s non-public Personally Identifiable Information, such individual should contact UnitedLex by sending UnitedLex an email message at privacy@unitedlex.com to request access to, correct or delete any Personally Identifiable Information that you have provided to us. Prior to making any alterations in its information, UnitedLex will require that individuals confirm their identity.

Data Integrity
UnitedLex will use Personally Identifiable Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. UnitedLex will take reasonable steps to ensure that Personally Identifiable Information is relevant to its intended use, accurate, complete, and current.

Onward Transfer
UnitedLex will comply with the notice and choice principles as described above for all data which is disclosed or transferred to a third party. UnitedLex may share personal information with its subsidiary or parent or its affiliate entity such as its joint venture partners, only in connection with tendering of client services, where such subsidiary or parent or the affiliate entity is involved in the management of the specific matter in question. In such instances, information may be shared or transferred, depending on the client instructions from UnitedLex Corporation to such UnitedLex Corporation subsidiary or parent or affiliated entity, which may involve transfer of data from the United States of America to India.

UnitedLex will obtain assurances from its agents that they will safeguard Personally Identifiable Information consistently with this Policy. UnitedLex will require that its agents either: (i) subscribe to the EU Safe Harbor Principles, the EU Data Protection Directive or another adequacy finding; or (ii) enter into a written agreement with UnitedLex requiring them to provide the same level of protection as UnitedLex.

Security
UnitedLex will take reasonable precautions to protect Personally Identifiable Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. UnitedLex limits access to Personally Identifiable Information and data to those persons in the UnitedLex organization, or agents of UnitedLex, that have a specific business purpose for maintaining and processing such information and data. Individuals who have been granted access to Personally Identifiable Information are aware of their responsibilities to protect the security, confidentiality and integrity of that information.

Access
Upon request, UnitedLex will grant individuals reasonable access to Personally Identifiable Information that it holds about them. In addition, UnitedLex will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. UnitedLex agrees to process all reasonable requests for access within a reasonable time period, but reserves the right to deny access or limit access in cases where the burden or cost of providing access would be disproportionate to the risks to the individual’s privacy or in the case of a vexatious or fraudulent request.

Enforcement
Individuals who wish to file a complaint or who take issue with this Policy should direct such communication to UnitedLex via e-mail at the address provided above. UnitedLex will explain the process to be followed when filing a complaint. Filing a complaint in English will expedite the process. UnitedLex will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personally Identifiable Information in accordance with the principles contained in this Policy. Complaints that cannot be resolved between UnitedLex and the complainant will be submitted to the American Arbitration Association (“AAA”) for mediation and, if necessary, to binding arbitration for final resolution. Information about AAA services can be found at its website: www.adr.org.

Comments
If you have any questions, comments or concerns about our privacy practices, please contact us by email at privacy@unitedlex.com or telephone at 1.888.385.3725.

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