Privacy Shield Policy
We recognize that the EEA, UK, and Switzerland have established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EEA, the UK, and Switzerland. To provide adequate protection for certain Personal Data about clients, business partners, and human resource data received in the US from the EEA, the UK, and Switzerland, we have elected to self-certify to the EU-US Privacy Shield Framework and the EU-US Privacy Shield Framework administered by the US Department of Commerce ("Privacy Shield"). The Company adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.
For purposes of enforcing compliance with the Privacy Shield, the Company is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce's Privacy Shield website located at: https://www.privacyshield.gov. To review the Company's representation on the Privacy Shield list, see the US Department of Commerce's Privacy Shield self-certification list located at: https://www.privacyshield.gov/.
Personal Data Collection and Use
We may receive the following categories of Personal Data in the US: on-line, off-line, customer and supplier data, and human resources data. Further, we process Personal Data for the following purposes: customer, supplier, payroll, and human resources reporting. The Company will only process Personal Data in ways that are compatible with the purpose that we collected it for, or for purposes the individual later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. The Company maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.
We may collect the following categories of sensitive Personal Data: individual's racial or ethnic origin, age, political or religious beliefs, trade-union membership, physical or mental health, or sexual life. We process sensitive Personal Data for the following purposes: customer, supplier, payroll, and human resources reporting. When we collect sensitive Personal Data, we will obtain your opt-in consent where the Privacy Shield requires, including if we disclose your sensitive Personal Data to third parties, or before we use your sensitive Personal Data for a different purpose than we collected it for or than you later authorized.
Data Transfers to Third Parties
Third-Party Agents or Service Providers.
Third-Party Data Controllers.
Disclosures for National Security or Law Enforcement.
Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
The Company maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield. Further, the Company has various controls and procedures in place for self-assessment to ensure it is in full compliance with the Privacy Shield principles.
You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your Personal Data to us at:
Howard and Howard Attorneys PLLC
Attention: Roger Heater
450 West Fourth Street
Royal Oak, Michigan 48067
We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with European Union (EU) Data Protection Authorities. If you are unsatisfied with the resolution of your complaint, you may contact the EU data protection authorities at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm for further information and assistance.
Binding Arbitration You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with the Company and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration).
If you have any questions about this Policy or would like to request access to your EEA Personal Data, please contact us as follows: [email protected].
Changes To This Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy Shield's requirements.
Effective Date: October 17, 2019
Last modified: October 17, 2019