ARG LLC’s Privacy Shield Statement
ARG LLC recognizes that the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield are no longer valid transfer mechanisms for personal information from the European Union and its Member States, the European Economic Area, or Switzerland. The U.S. Department of Commerce, which oversees compliance with Privacy Shield, has stated that it will nonetheless continue to administer the Privacy Shield program and that participants are not relieved of their obligations under Privacy Shield. Accordingly, ARG LLC, as a participant in the Privacy Shield program, will continue to comply with its commitments under the Privacy Shield (as described more fully below) and its robust internal data protection policies.
We respect the confidentiality and privacy of our clients, our people and others with whom we do business. ARG LLC complies with the requirements of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce (the “Principles”). ARG LLC has certified that it adheres to the Principles with respect to personal information (as described below) that is transferred from the European Union and its Member States, the European Economic Area, the United Kingdom and/or Switzerland (“EU”) to the United States. If there is any conflict between the terms in this Privacy Shield Policy and the Principles, the Principles shall govern. ARG LLC is subject to investigatory and enforcement powers of the U.S. Federal Trade Commission.
This Privacy Shield Policy applies to personal information within the scope of ARG LLC’s Privacy Shield certification, which covers the following categories of information:
- Personal information regarding current, former and prospective partners, principals and employees for the purposes of operating and managing ARG LLC, performing human resource administration, and maintaining contact with individuals.
- Personal information regarding current, former and prospective clients and their personnel or others for the purposes of delivering ARG LLC services, maintaining ongoing relationships and performing business development activities.
- Personal information regarding our third parties (e.g., vendors, service providers, etc.) and their personnel for the purposes of managing and administering ARG LLC’s business relationships with such third parties.
- Additionally, ARG LLC may, from time to time, collect personal information from the general public in order to answer inquiries or information requested
For the purposes of this Privacy Shield Policy, “personal information” means information that is about, or pertains to a specific individual and can be linked either directly or indirectly to that individual.
Individual Notice and Choice
We collect and process personal information from certain individuals and for the purposes described in this Privacy Shield Policy. Personal information covered by this Privacy Shield Policy is collected and processed only as permitted by the Principles.
Notice to individuals regarding the personal information collected from them and how that information is used may be provided through this Privacy Shield Policy, other ARG LLC website notices, or other direct forms of communication with appropriate parties, such as contracts or agreements. Where necessary and appropriate, consent for personal information to be collected, used, and/or transferred may also be obtained through these same means of communication (including opt-in consent for sensitive personal information).
Disclosures & Accountability for Onward Transfers
Consistent with the Principles, ARG LLC may transfer personal information to third parties, including transfers from one country to another. We will only disclose an individual’s non-public personal information to third parties under one or more of the following conditions:
- The disclosure is to a third party providing services to ARG LLC, or to the individual, in connection with the operation of our business, and as consistent with the purpose for which the personal information was collected. We maintain written contracts with these third parties and require that these third parties provide at least the same level of privacy protection and security as required by the Privacy Shield Principles. To the extent provided by the Principles, ARG LLC remains responsible and liable under the Privacy Shield Principles if a third-party that it engages to process personal information on its behalf does so in a manner inconsistent with the Privacy Shield Principles unless ARG LLC proves that it is not responsible for the matter giving rise to the damage;
- With the individual’s permission to make the disclosure;
- Where required to the extent necessary to meet a legal obligation to which ARG LLC is subject, including a lawful request by public authorities and national security or law enforcement obligations and applicable law, rule, order, or regulation.
- Where reasonably necessary for compliance or regulatory purposes, or for the establishment of legal claims.
Individuals whose personal information is covered by this Privacy Shield Policy have the right to access the personal information that ARG LLC maintains about them as specified in the Principles. Individuals may contact us to correct, amend or delete such personal information if it is inaccurate or has been processed in violation of the Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated). Requests for access, correction, amendment or deletion should be sent to ARG LLC’s Privacy Office.
ARG LLC takes appropriate measures to protect personal information in its possession to ensure a level of security appropriate to the risk of loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures take into account the nature of the personal information and the risks involved in its processing, as well as best practices in the industry for security and data protection.
Data Integrity and Purpose Limitation
ARG LLC collects and processes personal information only to the extent that it is compatible with the purposes for which it was collected or subsequently authorized by the data subject. ARG LLC does not retain personal information after it no longer serves the purposes for which it was collected or subsequently authorized. ARG LLC takes reasonable steps to ensure that personal information is accurate, complete, current, and reliable for its intended use.
In compliance with the Principles, ARG LLC commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact ARG LLC’s Privacy Office. ARG LLC has a policy of responding to individuals within forty-five (45) days of an inquiry or complaint. If the dispute involved human resources personal information or information collected in the context of an employment relationship, we will cooperate with the competent EU or Swiss data protection authorities and comply with the advice of such authorities.
You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances. For further information, please see the Privacy Shield website. To learn more about the Privacy Shield Framework, and to view ARG LLC’s certification, please visit https://www.privacyshield.gov.