Lamparth Consulting, Inc. Safe Harbor Privacy Policy

Lamparth Consulting, Inc. Safe Harbor Privacy Policy

To provide an adequate level of protection for Personal Data received from the European Union (EU). Lamparth Consulting, Inc. (“LC” or “the Company”) adheres to the Safe Harbor Principles developed by the United States Department of Commerce and the European Commission and Switzerland. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles that LC follows when processing Personal Data received from the EU. The privacy principles in this Policy are based on the Safe Harbor Principles referenced above. To learn more about the Safe Harbor program, and to view LC’s certification, please visit

http://www.export.gov/safeharbor/ .

LC’s Role as a Global IT Consulting Company

LC is an IT Consulting and Servicing Company with clients throughout Europe and Asia. LC manages international IT Infrastructure for clients located in Europe. As part of managing IT Infrastructure, LC has access to account relevant data such as usernames.

LC’s Compliance with Safe Harbor Principles

In order for LC to provide IT consulting services, LC may be required to transfer client data, including personal data, to the United States.

Without the client’s or prospective client’s prior, written authorization, transfers will consist exclusively of remote access by LC employees located in the U.S. to Personal Data physically in the EU.  LC will not physically transfer any Personal Data stored in the EU to the U.S. without the client’s or prospective client’s prior, written consent.

LC will apply the following Safe Harbor Principles to Personal Data transferred to the U.S., whether physically or by remote access:

Onward Transfer

LC will not disclose Personal Data to a third party, for any reason. If LC learns that an employee or other individual is using or disclosing Personal Data in a manner contrary to this Policy, LC will take reasonable steps to prevent such use or disclosure.

LC may disclose Personal Data as required by law, for example, in response to a court order or subpoena.  Before making any such disclosure, LC will promptly inform the client or prospective client, so it may take such actions as it deems necessary to protect the rights of Data Subjects.

Security for Personal Data

LC is committed to safeguarding the Personal Data that it receives from the EU. While LC cannot guarantee the security of Personal Data, the Company takes reasonable precautions to protect Personal Data in the Company's possession from loss, misappropriation and unauthorized access, disclosure and destruction. LC utilizes a combination of online and offline security technologies, procedures and organizational measures to help safeguard Personal Data. 

Enforcement

LC will conduct periodic self-assessments of its relevant practices to verify adherence to this Policy and the Safe Harbor Principles.  Any employee who intentionally violates this Policy will be subject to disciplinary action up to and including termination of employment.  Clients who have a complaint concerning LC’s processing of Personal Data should contact LC’s Human Resources Department by emailing nicole@lamparth.com.

Clients of LC who are not satisfied with the internal resolution of a complaint may seek redress by submitting a complaint to the Council of Better Business Bureaus, Inc. Please visit https://www.bbb.org/consumer-complaints/file-a-complaint/get-started to file a complaint.

Changes to this Privacy Policy

LC may revise this policy at any time. If the Company decides to materially change this policy, the Company will post the revised Policy at this location. 

 

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