Stroz Friedberg welcomes visitors to our website and to encourage such visits, we are committed to protecting the privacy of information provided by visitors. This Privacy Policy describes what Stroz Friedberg does to protect the privacy of information provided by visitors to our website.
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 email@strozllc.com, with “privacy” in the subject line. Any opt-out request will be processed as promptly as practicable.
From time to time, we may use information provided by visitors to our website for new, unanticipated uses not previously disclosed in our privacy policy, which will then be updated. We reserve the right to disclose information collected from visitors to our web site as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on us.
Cookies
A "cookie" is a small data file placed on your web browser and stored on your computer's hard drive. Stroz Friedberg does not use cookies to collect information about visitors to our website. Cookies from our website are used solely for management of the site. If you have configured your browser to disable cookies, you may still browse and download material from our website.
Changes in Privacy Policy
This Privacy Policy may occasionally be updated. When material updates are made, the date of the last revision will be reflected at the end of the page. If you are concerned about how your information is used, we encourage you to bookmark this page and review this Privacy Policy periodically to note recent updates.
Questions
If you have any questions or concerns about this policy, you may contact Stroz Friedberg via e-mail at email@strozllc.com, with “privacy” in the subject line, or at the postal address: Stroz Friedberg, 32 Avenue of the Americas, 4th Floor, New York, NY 10001, 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 certified by 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: February 14, 2008
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 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 has a separate Privacy Policy that applies to and is accessible on our web site, regarding the collection and use of personal information from visitors to the web site.
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:
Client Personal Data processed by Stroz Friedberg may be subject to contractual agreements with our clients that require more stringent privacy and security safeguards than the requirements in the Safe Harbor Agreement. At a minimum, however, Stroz Friedberg handles Client Personal Data in accordance with our Safe Harbor Privacy Policy, which is based upon the seven principles identified in the Safe Harbor Privacy Framework.
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.
In the event that Stroz Friedberg ever needs to transfer Client Personal Data to an unrelated third party, Stroz Friedberg will ensure that such party is either subject to the Safe Harbor Agreement, subject to similar laws providing an adequate and equivalent level of privacy protection, or will enter into a written agreement with the third party requiring them to provide protections consistent with the Safe Harbor Privacy Framework and Stroz Friedberg’s Safe Harbor Privacy Policy. Should Stroz Friedberg learn that an unrelated third party to which Personal Data has been transferred by Stroz Friedberg is using or disclosing Personal Data in a manner contrary to this Policy, Stroz Friedberg will take reasonable steps to prevent or stop the use or disclosure.
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.
Enforcement: Stroz Friedberg assures compliance with this Safe Harbor Privacy Policy and the Safe Harbor Privacy Framework by utilizing the self-assessment approach. The self-assessment is conducted on an annual basis to ensure that all of Stroz Friedberg's relevant privacy practices are being followed in conformance with this Safe Harbor Privacy Policy and the Safe Harbor Privacy Framework. Any employee that Stroz Friedberg determines is in violation of these policies will be subject to discipline, up to and including termination of employment.
Stroz Friedberg will also assure compliance with this Safe Harbor Privacy Policy and the Safe Harbor Privacy Framework by fully investigating and attempting to resolve any complaint or dispute regarding the use and disclosure of personal data in violation of this Privacy Policy.
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.
Questions: Clients or prospective clients of Stroz Friedberg with questions or concerns about Stroz Friedberg’s compliance with this Safe Harbor Privacy Policy, may contact us via email at
email@strozllc.com, with “privacy” in the subject line, or at the postal address: Stroz Friedberg, 32 Avenue of the Americas, 4th Floor, New York, NY 10001, ATTN: PRIVACY.
Safe Harbor Privacy Policy Updates: This Safe Harbor Privacy Policy may occasionally be updated. When material updates are made, the date of the last revision will be reflected at the end of the page. This page may be bookmarked to facilitate periodic review of this Safe Harbor Privacy Policy and to note recent updates. Neither this Safe Harbor Privacy Policy nor updates to it will affect or modify any contracts we have with our clients.
Last update: February 14, 2008