Privacy CRA International, Inc. and each of its affiliates and subsidiaries (collectively, “CRA”) is committed to meeting all of our obligations to our clients and visitors worldwide to protect their data and to collect, use, and disclose it for authorized purposes only. CRA is equally committed to abiding by all applicable domestic, national, and international privacy laws. Like most businesses providing services to clients, CRA may acquire personally identifiable information (also known as personal data) of its clients and their employees, and of its other visitors. In general, data collected, used, or disclosed by CRA is processed by CRA on behalf of and as directed by our clients. When CRA does process personally identifiable information on its own behalf, CRA conforms to recognized privacy principles and practices, including notice, choice, consent and control, fairness and integrity, as provided by applicable industry and international legal standards. Scope As an economics, finance, and business consulting firm that works with businesses, law firms, accounting firms, and governments in providing a wide range of services (“Services”), CRA not only is committed to the privacy of its clients but is equally committed to the privacy of those who visit our websites. Our Privacy Notice applies to all CRA activities, including the production of our websites. Both our Privacy Notice and our long-established business principles commit us to keeping your personal information appropriately protected. For the purposes of applicable data protection law, CRA International, Inc. is the controller of any personal data collected from you on CRA’s websites. If your personal data is collected in the course of CRA providing its Services to a client, the data controller will be the CRA entity that has been engaged to provide those Services. Information we collect Every computer connected to the Internet has a domain name and a set of numbers that serve as that computer’s “Internet protocol” (IP) address. When a visitor requests a page from one of our websites, our web servers automatically recognize that visitor’s domain name and IP address. The domain name and IP address reveal nothing personal about you other than the IP address from which you have accessed our website. From time to time, we examine our traffic in aggregate to help us improve our websites, to maintain quality of the service, and to provide general statistics regarding use of the websites. Under no circumstances do we sell, rent, or give your e-mail address to a third party for the purpose of that party sending you “spam mail” or otherwise using your email address in any way not directly associated with CRA providing its Services to you. Our websites collect and store client and website user information. This information may include names, company names, addresses, telephone numbers, facsimile numbers and email addresses. In addition, CRA may ask employees of clients for website addresses, service interests, credit-related information with respect to service retention, and other information. We routinely collect personal data – which may relate to employees, customers, or other third parties – from our clients in the course of providing our Services to them. This personal data will be requested by CRA only where it is reasonably required in order to provide our Services, in accordance with our terms of engagement. If you represent one of CRA’s clients or prospective clients, we may collect and keep your business contact information in a variety of ways, including through face-to-face meetings, public directories or networking sites, and other professional encounters. Cookies A cookie is a text file that is placed on your computer’s hard drive or other electronic storage device by a web page server. We use cookies to obtain some of the information that is collected automatically as described above. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can be read only by a web server in the CRA domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time by telling the web server that you have returned to a specific page. Cookies can be deleted from your system at any time. You also have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the websites you visit. For more information about cookies including how to set your web browser to reject cookies please go to www.allaboutcookies.org. By continuing to use our websites, you agree to our use of cookies in accordance with this Privacy Notice. Different types of cookies are used for different purposes on our websites. These are known as strictly necessary cookies, performance cookies, and functionality cookies. Some cookies may be provided by an external third party to provide additional functionality to our website; these are described below. Strictly necessary cookies These are cookies that are essential to fulfill an action requested by you, such as identifying you as being logged in. If you prevent these cookies by adjusting your browser settings we cannot guarantee how our websites will perform during your visit. Performance cookies These are cookies used to improve our website, for example for analytics that let us see how our websites is being used and where to make improvements. These cookies are used to collect information about how visitors use our websites. The information is collected in an anonymous form and includes the number of visitors, where visitors have come from to the websites and the pages they visited. Functionality cookies These cookies enhance the performance and functionality of our website, often as a result of something you are doing as a user. For instance, we may personalize our content for you or remember your preferences. Use of personal information When processing personal information, CRA adheres to applicable domestic, national, and international data privacy laws. The personal information we collect is used for the purposes below. Where relevant under applicable law, all processing (i.e., use and storage) of your personal information will be justified by a “condition” for processing. In the majority of cases, processing will be justified on the basis that: you have consented to the processing; the processing is necessary to perform a contract with you or take steps to enter into a contract; the processing is necessary for us to comply with a relevant legal obligation; or the processing is in our legitimate commercial interests, subject to your interests and fundamental rights. We use the personal information we collect to: deliver our Services to our clients; help us maintain the quality of our websites and the Services we offer generally; operate and customize our websites to users’ needs; enable you to subscribe to and receive CRA’s news services and other additional CRA Services, and enable CRA to deliver to you those Services that you have requested; correspond with users to resolve their queries or complaints; market our Services to our clients; manage client relationships; and comply with applicable laws and regulations. Our Website uses cookies to: help our clients and visitors personalize their online experience; and identify users and track trends among clients and other users who visit our websites. Our websites may request your email or mailing address for the purpose of providing you with further information, administering online registrations to courses and similar events run by CRA, or in association with other organizations such as universities CRA also makes every effort to keep personal information up-to-date and we welcome our clients and visitors to access and update this personal information. Except for disclosure amongst the members of CRA and its subsidiaries, CRA does not sell lists, accept advertising, or generate any third-party revenue from the data that is generated on this website. Disclosure of personal information CRA does not disclose personal information to third parties except where we may make this information available (i) to outside contractors working on client-specific projects bound by written obligations of confidentiality and non-disclosure; or (ii) to outside mailing houses bound by written obligations of confidentiality and non-disclosure, working under CRA’s direction to provide CRA mailings to our clients. In relation to both internal transfers and the use of service providers, if personal information is transferred outside your local jurisdiction (e.g., the European Economic Area, “EEA”), we will take steps, where required by applicable law, to ensure that the information receives the same level of protection as if it remained within your local jurisdiction. CRA is accountable for the onward transfer of personal information to third-party service providers or agents who assist us in providing services. We maintain contracts with these third parties in compliance with our obligations under applicable data protections laws and other obligations. We accept liability if any of these parties fail to process the personal information transferred in a manner consistent with applicable law, unless we demonstrate that we are not responsible for the event giving rise to the damage. For internal transfers, we have put in place an Intra Group Data Transfer Agreement which protects personal data transferred between global CRA entities. For EU and UK residents, you may have a right to details of the mechanisms under which your data is transferred outside of the EEA or UK, as the case may be. In addition, CRA recognizes standard domestic and international legal and public policy exceptions to non-disclosure. Important exceptions to the general rule of non-disclosure without permission have been codified internationally in such privacy laws as the General Data Protection Regulation (EU) 2016/679, the UK Data Protection Act 2018, Title V of the US Financial Services Modernization Act in 1999, Canada’s Personal Information Protection Act (C-6), and Australia’s Privacy Act 1988. As such, CRA may therefore collect, use, and disclose personal information necessary for the establishment, exercise, or defense of legal claims, or in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. As provided by applicable US federal law (or applicable local laws), CRA may also disclose personal information without the consent of an individual to protect against or prevent actual or potential fraud, for institutional risk control, for the enforcement of contractual obligations, to resolve client disputes or injuries, and for various other purposes provided by law. Marketing communication Where lawful to do so, we may communicate with you to tell you about our products and Services. If you do not wish us to use personal information about you in order to inform you about Services and courses provided by CRA, news on industry developments, or other corporate and industry-related announcements, please contact us using the information in the “Contact Information” section at the bottom of this page. You can also use the <Unsubscribe> link provided in our emails Security of your personal information CRA uses data storage and security techniques to protect your personal information from unauthorized access, use, or disclosure, unauthorized modification or unlawful destruction or accidental loss. CRA secures personally identifiable information on computer servers in a controlled, secure environment. Personal information gathered through our websites is transmitted only within the CRA domain and is protected through the use of encryption and/or other means. However, it is important to remember that no website can be 100% secure and we cannot be responsible for unauthorized or unintended access that is beyond our control. Retention of your information We apply a general rule of keeping personal information only for as long as required to fulfil the purposes for which it was collected. However, in some circumstances we may retain personal information for longer periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements. In specific circumstances we may also retain your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges. External links Please note that the websites may contain links to third party sites and if you link to a third party site from CRA, any information you provide to that site and any use of that information by the third party are not under the control of CRA and are not subject to this Privacy Notice. You should consult the privacy policies of each site you visit. This Privacy Notice applies solely to personal information collected by our websites. Your rights Subject to applicable law, you may have some or all of the following rights in respect of your personal information: the right to access your own personal data subject to certain limitations, such as where the legitimate rights of other persons would be infringed or where the burden or expense of providing access would be disproportionate; to obtain a copy of your personal information together with information about how and on what basis that personal information is processed; to rectify inaccurate personal information (including the right to have incomplete personal information completed); to erase your personal information (in limited circumstances, where it is no longer necessary in relation to the purposes for which it was collected or processed); to restrict processing of your personal information where: the accuracy of the personal information is contested we no longer require the personal information but it is still required for the establishment, exercise or defence of a legal claim; to challenge processing which we have justified on the basis of a legitimate interest (as opposed to your consent, or to perform a contract with you); to prevent us from sending you direct marketing; to withdraw your consent to our processing of your personal information (where that processing is based on your consent); to object to decisions that are based solely on automated processing or profiling; and to obtain, or see a copy of the appropriate safeguards under which your personal information is transferred to a third country or international organization. In relation to all of these rights, please contact us using the details given below. Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We will endeavor to respond to your requests within all applicable timeframes. Changes to this statement CRA will occasionally update this Privacy Notice to reflect company and user feedback. CRA encourages you to periodically review this Privacy Notice to be informed of how CRA is protecting your information. Contact and Enforcement CRA welcomes your comments regarding this Privacy Notice. If you have any questions relating to this Privacy Notice, believe that CRA has not adhered to this Privacy Notice, wish to exercise any of your rights, or if you have any suggestions or problems, please contact us at: Charles River Associates Privacy and Compliance 200 Clarendon Street Boston, MA 02116-5092 United States +1-800-862-1895 Email: PrivacyMatters@crai.com We will use all reasonable efforts to promptly determine and remedy any problems reported to us. CRA has a practice of responding to individuals within forty-five (45) days of an inquiry or complaint. CRA has further committed to refer unresolved privacy complaints to an independent dispute resolution mechanism, the JAMS Privacy Shield Program. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint. 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