Information Collection and Use
Stroz Friedberg does not sell, rent, exchange or otherwise disclose our mailing lists or information about visitors to our website.
Stroz Friedberg does not track visitors to our website. Our website captures limited information about visits to our site that is used only to analyze general traffic patterns (e.g., what pages are most/least popular, the domain name and name of the Web page from which the visitor entered our Web site, the pages visited on our Web site and how much time is spent on each page on our Web site) and to perform routine system maintenance.
Contact information voluntarily provided by visitors, who have a specific inquiry, will be used to respond to that inquiry. In addition, this contact information will be added to our promotional mailing list, which we use for distribution of our electronic newsletter, Stroz Friedberg Advisor, and other announcements or promotional material.
Out of respect for your privacy, when we send our electronic newsletter, Stroz Friedberg Advisor, or other announcements or promotional material, we provide a way to unsubscribe and opt not to receive this material in the future. If you do not wish to be added to, or wish to be removed from, our promotional mailing list, please follow the unsubscribe instructions generally located at the bottom of the newsletter or the e-mail announcements, or send us an email at firstname.lastname@example.org, with “privacy” in the subject line. Any opt-out request will be processed as promptly as practicable.
If you have any questions or concerns about this policy, you may contact Stroz Friedberg via e-mail at email@example.com, with “privacy” in the subject line, or at the postal address: Stroz Friedberg, 32 Avenue of the Americas, 4th Floor, New York, NY 10013, ATTN: PRIVACY.
Certified Compliant With EU Safe Harbor Principles
Stroz Friedberg complies with the European Union Safe Harbor Principles regarding the collection and use of personal information obtained from clients in the European Union, and is self-certified with the US Department of Commerce as compliant under the Safe Harbor framework. The Safe Harbor framework became effective on November 1, 2000 and meets the European Union Directive on Data Protection’s requirement to provide “adequate” privacy protection. For further information, see Stroz Friedberg’s Compliance with EU Safe Harbor Principles.
Last update: March 31, 2009
Stroz Friedberg’s Certified Compliance with EU Safe Harbor Principles
Stroz Friedberg is committed to maintaining the privacy and confidentiality of "Personal Data" (as defined below) entrusted to Stroz Friedberg by our clients and their legal counsel. Accordingly, Stroz Friedberg adheres to and is self-certified as complaint with the Safe Harbor Privacy Framework between the United States Department of Commerce and the European Commission with respect to Personal Data that is transferred from the European economic area to the United States.
For further information about the Safe Harbor Privacy Framework and the documents that comprise its requirements, see the U.S. Department of Commerce web site at http://www.export.gov/safeharbor/.
Stroz Friedberg's Business Purposes for the Collection and Use of Personal Data.
Stroz Friedberg provides digital forensics, electronic discovery, cyber-security and private investigative services to companies and the law firms that represent them. In connection with providing these services, Stroz Friedberg obtains two types of information from our clients:
Contract information is provided by our clients in connection with contracting for our services and typically includes the name, address and other contact information of the client. This information is used for the administration of contracts and invoicing, and internally for forecasting, budgeting, accounting, auditing, financial reporting and other due diligence purposes in connection with acquisition transactions.
Client Personal Data is information from equipment and networks owned, controlled or operated by our clients that is received by Stroz Friedberg for purposes of collection, processing, storage and analysis in accordance with the instructions of the clients and/or their legal advisors and in order to assist clients in meeting their legal or professional obligations, protecting their vital interests or carrying out other legitimate activities. Stroz Friedberg will not use Client Personal Data for any other purposes than for the purposes that Stroz Friedberg's client provides such information.
Stroz Friedberg’s Adherence to Seven Safe Harbor Principles:
Consistent with the Safe Harbor Privacy Framework, various principles are limited when a client transfers custody of data to Stroz Friedberg for processing on the instructions of a client or that client’s legal counsel. In those circumstances, Stroz Friedberg receives the Client Personal Data from the European Union as an agent of the client merely for processing and is not required to apply the Notice, Choice, Data Integrity and Access principles to that information. The client will remain responsible for the Client Personal Data and complying with applicable privacy laws and directives.
Notice: When Stroz Friedberg receives Client Personal Data for processing pursuant to instructions of clients or their legal counsel, we are acting as an agent for our client and do not provide notice to individuals regarding the collection and use of their personal data. Our clients remain responsible for providing notice, if and to the extent they believe such notice is necessary under applicable EU law.
Choice: When Stroz Friedberg receives Client Personal Data from individuals in the European Union pursuant to instructions of clients or their legal counsel, we are acting as an agent for our client and do not provide choice to individuals regarding the collection and use of their personal data. Our clients remain responsible for providing choice, if and to the extent they believe such notice is necessary under applicable EU law.
Onward Transfer: Stroz Friedberg does not transfer Client Personal Data to unrelated third parties, unless lawfully directed by a client, or in certain limited or exceptional circumstances in accordance with the Safe Harbor Privacy Framework. For example, such circumstances would include disclosures of Client Personal Data required by law or legal process, or disclosures made in the vital interest of an identifiable person such as those involving life, health or safety.
Where we do transfer data to vendors for additional processing, it will be at the direction of our clients, making the vendor an agent of the client, and not an agent of Stroz Friedberg. Accordingly, each time we send data to vendors, we must ensure a transmittal letter accompanies the data that reflects that the data is being provided “at the direction of [client name].”
Security: Stroz Friedberg is committed to the security of all personal data. Stroz Friedberg takes all reasonable physical, electronic, and managerial precautions to protect Client Personal Data in its possession from unauthorized access, disclosure, alteration, destruction, tampering, loss or misuse.
Data Integrity: Stroz Friedberg does not modify or alter in any way Client Personal Data but preserves such data in its original form to the extent possible, consistent with any processing that is directed by clients or necessary to fulfill the services requested by clients or their legal counsel.
Access: Contract information and Client Personal Data is accessible by only those Stroz Friedberg employees and consultants who have a reasonable need to access such information in order for us to fulfill contractual, legal and professional obligations. All of our employees and consultants have entered into confidentiality agreements requiring that they maintain the confidentiality of Client Personal Data.
Due to the nature of the services Stroz Friedberg provides and security concerns, the burden, expense and security risks of providing individual access to Client Personal Data would be disproportionate with risks to the individual's privacy in the case in question. Such access would risk violating the rights of persons other than the individuals seeking access and would increase the security risks. Therefore Stroz Friedberg cannot provide individuals with access to Client Personal Data in order to correct, amend, or delete information that is demonstrated to be inaccurate.
For complaints that cannot be resolved by Stroz Friedberg and the complainant, Stroz Friedberg agrees to cooperate with data protection authorities located in the European Union (or their authorized representative) and participate in dispute resolution procedures of those authorities, pursuant to the Safe Harbor Privacy Framework.