Alexander Group Privacy Shield Policy – May 1, 2018
The Alexander Group, Inc. (“The Alexander Group or Alexander Group”) has adopted this Privacy Shield Policy (“Policy”) to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that The Alexander Group obtains from Customers.
All Alexander Group employees who handle Personal Data from Europe are required to comply with the Principles stated in this Policy.
Capitalized terms are defined in Section 14 of this Policy.
This Policy applies to the processing of Customer Personal Data that The Alexander Group receives in the United States concerning Customers who reside in Europe. The Alexander Group provides Go-To Customer business strategy services to companies around the world.
This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)
- RESPONSIBILITIES AND MANAGEMENT
The Alexander Group has designated an internal team to oversee its information security program, including its compliance with the Privacy Shield program. The internal team shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to firstname.lastname@example.org.
The Alexander Group will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. The Alexander Group personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that The Alexander Group has undertaken to protect Personal Data.
III. RENEWAL / VERIFICATION
The Alexander Group will renew its Privacy Shield certification annually, unless it subsequently determines that it no longer needs such certification or if it employs a different mechanism to adequately meet EU data protection regulations.
Prior to the re-certification, The Alexander Group will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, The Alexander Group will undertake the following:
- Ensure that this Policy continues to comply with the Privacy Shield principles
- Confirm that Customers are made aware of the process for addressing complaints and any independent dispute resolution process (The Alexander Group may do so through its publicly posted website, Customer contract, or both)
- Review its processes and procedures for training Employees about The Alexander Group’s participation in the Privacy Shield program and the appropriate handling of Customer Personal Data
- COLLECTION AND USE OF PERSONAL DATA
The Alexander Group provides various services to its B2B Customers. The Alexander Group collects Personal Data from Customers when they purchase our services, sign up for our newsletters, download white papers, complete surveys, request information from us, or otherwise communicate with us.
The Personal Data that we collect may vary based on the Customer’s interaction with our website and request for our services. As a general matter, The Alexander Group collects the following types of Personal Data from its Customers: contact information, including, a contact person’s name, work email address, work mailing address, work telephone number, job title, and company name.
When Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website.
For certain services, The Alexander Group serves as a data processor to its Customers. In our capacity as a data processor, we will receive, store, and/or process Personal Data owned and/or controlled by our Customers, including information about their employees, clients, agents, or other individuals. In such cases, as a data processor, we will process the personal information on behalf of and under the direction of each particular Customer. The information that we collect from our Customers in this capacity is used for delivering reports, individual and in aggregate, and providing strategic advice and or assisting with operations related to challenges faced by our Customer, and as otherwise requested by the Customer.
The Alexander Group uses Personal Data that it collects directly from its Customers indirectly in its role as a data processor for the following business purposes, without limitation: (1) maintaining and supporting its services, delivering and providing the requested services, and complying with its contractual obligations related thereto (including reporting, invoices, renewals, and other operations related to providing services to a Customer); (2) satisfying any required governmental reporting; (3) storing and processing data, including Personal Data, in computer databases and servers located in the United States; (4) verifying identity; (5) as requested by the Customer or for other business-related purposes permitted or required under applicable local law and regulation; and (6) as otherwise required by law.
- DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA
Except as otherwise provided herein, The Alexander Group discloses Personal Data only to Third Parties who reasonably need to know such data. Such recipients must agree to abide by confidentiality obligations. Examples of Third Parties that may receive personal information include consultants that have been contracted on behalf of the Customer with which The Alexander Group is contracted, and will only be provided with advance written notice. All Third Parties receiving personal information must have a written confidentiality agreement in place between Customer and Third Party and The Alexander Group and Third Party that meets or exceeds Privacy Shield standards.
The Alexander Group may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, The Alexander Group may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by The Alexander Group and they must either: (1) comply with the Privacy Shield principles or another mechanism permitted by the applicable European data protection law(s) for transfers and processing of Personal Data; or (2) agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy. The Alexander Group also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure.
The Alexander Group may be forced to disclose an individual’s personal information when compelled by a request made by a recognized public authority or where required to meet national security and or law enforcement requirements.
In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, The Alexander Group is potentially liable. The Alexander Group’s liability under this agreement will be governed by the contract in place between Customer and The Alexander Group.
- SENSITIVE DATA
The Alexander Group does not collect Sensitive Data (as defined under European Union data protection laws) from its Customers.
VII. DATA INTEGRITY AND SECURITY
The Alexander Group uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. The Alexander Group has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to The Alexander Group’s electronic information systems requires user authentication via password or similar means. The Alexander Group also employs access restrictions, limiting the scope of employees who have access to Customer Personal Data. Further, The Alexander Group uses secure encryption technology to protect certain categories of personal data. Finally, The Alexander Group is ISO 27001 certified and will continue to renew its certification annually unless it subsequently determines that it no longer needs such certification.
Despite these precautions, no data security safeguards guarantee 100% security all of the time.
- ACCESSING PERSONAL DATA
The Alexander Group personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
- RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
- Right to Access. As a data subject, you have the right to access your data at any time. Data subjects have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which The Alexander Group collected the Personal Data. Data Subjects may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law. Upon reasonable request and as required by the Privacy Shield principles, The Alexander Group allows Customers and their employees access to their Personal Data, in order to correct or amend such data where inaccurate.
Customers may edit their Personal Data by contacting The Alexander Group by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Customers should submit a written request to their local The Alexander Group office.
- Requests for Personal Data . The Alexander Group will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If The Alexander Group receives a request for access to his/her Personal Data from a Customer’s employee, then, unless otherwise required under law or by contract with such Customer, The Alexander Group will refer such Data Subject to Customer.
- Satisfying Requests for Access, Modifications, and Corrections. The Alexander Group will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.
- Limiting Use of Personal Data. You may request limitations on the use of your personal data specified in this agreement by contacting us at email@example.com.
- CHANGES TO THIS POLICY
This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees aware of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.
XII. QUESTIONS OR COMPLAINTS
Customers may contact The Alexander Group with questions or complaints concerning this Policy at the following address firstname.lastname@example.org.
XIII. ENFORCEMENT AND DISPUTE RESOLUTION
Customers or individuals with questions or concerns about the use of their Personal Data should contact us at email@example.com. In compliance with the Privacy Shield Principles, The Alexander Group commits to resolve complaints about our collection or use of your personal information.
As part of this agreement, The Alexander Group subjects itself to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Under certain conditions, more fully described on the Privacy Shield website (www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
“Customer” means a prospective, current, or former customer or client of The Alexander Group. The term also shall include any individual agent, employee, representative, customer, or client of a Customer where The Alexander Group has obtained his or her Personal Data from such Customer as part of its business relationship with the Customer.
“Data Subject” means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.
“Europe” or “European” refers to a country in the European Economic Area.
“Personal Data” as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual’s name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term “person” includes both a natural person and a legal entity, regardless of the form of the legal entity.
“Sensitive Data” means Personal Data that discloses a Data Subject’s medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.
“Third Party” means any individual or entity that is neither The Alexander Group nor an Alexander Group employee, agent, contractor, or representative.