Leaping the Chasm™ ("LTC") has international reach, with followers and supporters located throughout the world, including in the United Kingdom ("UK"), European Union ("EU") and Switzerland. In the course of its operations and through its interactions with LTC followers and supporters, LTC at times comes into custody of certain personal information. This Safe Harbor Policy (this "Policy") is being implemented pursuant to the framework of the U.S.-UK, U.S.-EU and U.S.-Swiss Safe Harbors and adheres to the Safe Harbor privacy principles contained therein. To learn more about the Safe Harbor program, please visit http://www.export.gov/safeharbor/. This Policy applies to all personal information received by LTC in the United States from the UK, EU and Switzerland.
1. Notice. Where LTC collects personal information directly from individuals in the UK, EU and Switzerland, it will inform them about the purposes for which it collects and uses personal information about them, the types of non-agent third parties to which LTC discloses that information, the choices and means, if any, LTC offers individuals for limiting the use and disclosure of personal information about them, and how to contact LTC.
Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to LTC, or as soon as practicable thereafter, and in any event before LTC uses or discloses the information for a purpose other than that for which it was originally collected. Where LTC receives personal information from other entities in the UK, EU and Switzerland, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
2. Choice. LTC will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For sensitive personal information, LTC will give individuals the opportunity to affirmatively and explicitly consent (opt-in) to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual, unless the purpose is necessary to establish legal claims or defenses.
3. Data Integrity. As a part of this Policy, LTC ensures that any personal information is relevant for the purposes for which it is used. LTC takes reasonable steps to ensure the data is reliable, accurate, complete, and current for its intended use.
4. Transfers. Personal information is not disclosed to third parties other than to certain entities providing services to LTC, and then only if such disclosure is permitted under applicable law and only if the third party operates in accordance with LTC's privacy and data security standards, and for the purposes of LTC's representation of its clients.
5. Access. Upon request, LTC will grant individuals reasonable access to personal information that it holds about them and will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete, unless such disclosure could interfere with private causes of action or a fair trial.
6. Security. LTC maintains physical, electronic, and procedural safeguards to protect the confidentiality and security of personal information it has received from the UK, EU and Switzerland.
7. Enforcement. LTC maintains strict security and confidentiality policies that govern all information any attorney or other personnel of LTC receives in the course of his or her employment or association with LTC. All attorneys and personnel are made aware of these policies and LTC has in place procedures to train all employees and affiliates in the implementation of these policies. Failure to adhere to LTC's privacy policies results in appropriate discipline. LTC has in place procedures for periodically conducting objective reviews of compliance with this Policy.
8. Verifications; Dispute Resolution. LTC's Legal Counsel will verify compliance with this Policy in a signed statement that will be updated annually. This Policy is accurate, comprehensive, fully implemented, and prominently displayed on the LTC website.
Any complaints concerning this Policy will be investigated, and if LTC is unable to resolve the complaint to the satisfaction of all parties, the parties agree to utilize the dispute resolution mechanisms provided for by JAMS (see http://www.jamsadr.com/).
9. Limitations. LTC's adherence to the Safe Harbor privacy principles may be limited (a) to the extent required to respond to legal or ethical obligations; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by applicable law or regulation.
10. Amendments. This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor privacy principles. If LTC decides to amend this Policy, it will inform you by posting the amended Policy on the LTC website. The amended Policy will go into effect on the revision date disclosed in the amended Policy.
This Policy was last revised on: September 2016.
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