Data Privacy Statement

INTRODUCTION

LDM Global, a premier information management, litigation support and professional services solutions provider specializing in data recovery, computer forensics, large scale electronic and paper based disclosure services and international projects, complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  LDM Global has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

LDM Global is subject to the investigatory and enforcement authority of the United States Federal Trade Commission (FTC).

 

SCOPE

This Privacy Shield Privacy Policy (the “Policy”) outlines LDM Global’s general policy and practices for implementing the Principles, including the types of information LDM Global gathers, how LDM Global uses it, and the notice and choice that affected individuals have regarding LDM Global’s use of and their ability to correct that information. This privacy policy applies to all personal information received by LDM Global whether in electronic, paper or verbal format.

This statement applies to all personal information we handle (except as noted below), including online, off-line, and manually processed data.

For purposes of this statement, “personal information” means information that:

  • Is transferred from the EU to the United States
  • Is recorded in any form
  • Is about, or pertains to, a specific individual and can be linked to that individual

It does not include information that pertains to a specific individual but from which that individual could not reasonably be identified.

 

DEFINTIONS

“Agent” means any third party that processes, collects, or uses Personal Information under the instructions of, and solely for, LDM Global or to which LDM Global discloses Personal Information for use on LDM Global’s behalf.

“Personal Information” or “Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

“Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

 

PRINCIPLES

NOTICE

LDM Global shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-Agent third parties to which LDM Global discloses or may disclose that Information. LDM Global shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and concise language when individuals are first asked to provide Personal Information to LDM Global, or as soon as practicable thereafter, and in any event before LDM Global uses or discloses the Information for a purpose other than for which it was originally collected.

 

CHOICE

LDM Global will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a non-Agent third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. The ability to opt out of above mentioned disclosure of Personal Information will be provided on the data collection questionnaire provided by LDM Global or the counsel representing you or your employer prior to data collection. For Sensitive Personal Information, LDM Global will give individuals the opportunity to affirmatively or explicitly (opt in) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. The ability to opt in to the above-mentioned use of Sensitive Personal Information activities will be provided on the data collection questionnaire provided by LDM Global or the counsel representing you or your employer prior to data collection.

 

DATA TYPES

LDM Global collects a range of data for the purpose of legal data processing. Data types may include names, addresses, telephone numbers, email addresses, and personal and/or confidential information related to general business, sales and marketing, mergers and acquisitions, contracts, personal correspondence, and other purposes as required by the underlying litigation requirements.

 

DISCLOSURES AND ONWARD TRANSFERS

Prior to disclosing Personal Information to a third party, LDM Global shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. LDM Global may disclose Private Information to its Agents for those Agents to obtain information needed to perform their functions. However, LDM Global’s Agents are restricted from using the Personal Information for purposes other than providing services for or to LDM Global. LDM Global requires that its Agents that have access to Personal Information agree in writing to provide an adequate level of privacy protection.

LDM Global also may disclose Personal Information as required by law, legal process, or mandatory professional standards. Before making any such disclosure, to the extent practical, LDM Global will take reasonable steps to inform the customer of the intended disclosure so that the individual may take such actions as it deems necessary to protect the Personal Information. When data processing is completed, LDM Global will provide access to the processed materials to the requesting law firm that ordered the data collection and processing event. It is LDM Global’s process to not disclose any personal data to any party except agent third parties such as the law firm managing the litigation, translation organizations to perform translation (if requested by the law firm), or eDiscovery engineering specialists and/or experts who may be required to support the law firm throughout the litigation. LDM Global will not knowingly provide access to Personal Information or Sensitive Personal Information to non-agent third parties other than the owner of the data and any party explicitly empowered by the data owner to receive said data. LDM Global may be required to disclose personal data in response to lawful requests from public authorities including to meet national security and law enforcement requirements.

LDM Global may be liable for the transfer of personal data to third parties.

 

DATA SECURTY

LDM Global takes our clients’ security seriously and undertakes every reasonable step to protect their information. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of our clients, LDM Global has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we process. However, we cannot guarantee the security of information on or transmitted via the Internet.

 

DATA INTEGRITY

LDM Global processes Personal Information only in ways compatible with the purpose for which it was collected or subsequently authorized by our clients. LDM Global will take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. LDM Global has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction.  LDM Global cannot guarantee the security of Information on or transmitted via the Internet.

 

ACCESS AND CORRECTION

LDM Global processes data under the guidance and direction of our clients. If an individual becomes aware that information we maintain about that individual is inaccurate, or if an individual would like to update or review his or her information, the individual must contact our client and proceed according to that client’s personal information policy. Individuals, under certain conditions, have the right to invoke binding arbitration.

 

ENFORCEMENT AND DISPUTE RESOLUTION

LDM Global utilizes the self-assessment approach to assure its compliance with our privacy statement. LDM Global periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Principles.

We encourage interested persons to raise any concerns with us using the contact information below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this policy.

In compliance with the Privacy Shield Principles, LDM Global commits to resolve complaints about our collection or use of an individual’s personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact LDM Global at:

info@ldmglobal.com

or

Privacy Office, LDM Global – U.S. Headquarters
PO Box 770791
Steamboat Springs, CO 80477

LDM Global has further committed to cooperate with the EU data protection authorities (DPAs) regarding unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship as well as non-HR data transferred from the EU.

If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.

Under certain conditions, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

 

PRIVACY STATEMENT CHANGES

This privacy statement may be changed from time to time. We will post any revised policy on this website, or a similar website that replaces this website.

 

INFORMATION SUBJECT TO OTHER POLICIES

We are committed to following the data protection regulations for all personal information. However, certain information is subject to policies of the firm that may differ in some respects from the general policies set forth in this statement.

  • Information relating to present or former LDM Global personnel is subject to our policies concerning personnel data privacy, which are available to current LDM Global personnel on LDM Global’s intranet (the Global Insider) and former LDM Global personnel upon request.
  • Information obtained from or relating to clients or former clients is further subject to the terms of any privacy notice to the client, any engagement letter or letters with the client, and applicable laws and professional standards.

 

CONTACT US

Questions, comments or complaints about LDM Global’s Data Privacy Statement or data collection and processing practices can be emailed to info@ldmglobal.com or mailed to:

Privacy Office, LDM Global – U.S. Headquarters
PO Box 770791
Steamboat Springs, CO 80477

 

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