Privacy Shield Policy

Last updated July 25, 2019

This Privacy Shield Policy (“Policy”) describes how Storm Management LLC and its parent, subsidiaries and affiliates in the United States (“US”) (individually referred to herein as “Storm” or “the Company” “we,” or “us”) collect, use, and disclose certain personally identifiable information that we receive in the US from the European Economic Area (“EEA”), the United Kingdom (“UK”), (“Personal Data”). This Policy supplements our Privacy Policy located at https://legal.stormmanagement-la.com/privacy-policy/, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Privacy Policy.

Storm recognizes that the EEA, the UK 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. To provide adequate protection for certain Personal Data about corporate customers, clients, business partners, job applicants, and employees received in the US from the EEA, the UK, Storm has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce (“Privacy Shield”). Storm 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 (the “Principles”).

For purposes of enforcing compliance with the Privacy Shield, Storm is subject to the investigatory and enforcement authority of the US Federal Trade Commission and/or Dept of Transportation. 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 Storm’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/participant?id=a2zt0000000CkYxAAK&status=Active.

Personal Data Collection and Use

Our Privacy Policy located at https://legal.stormmanagement-la.com/privacy-policy/ describes the categories of Personal Data that we may receive in the US as well as the purposes for which we use that Personal Data. 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. Storm maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.

Data Transfers to Third Parties, Third-Party Agents or Service Providers. We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf as described in our Privacy Policy. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection that Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.

Third-Party Data Controllers.

In some cases, we may transfer Personal Data to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your Personal Data to third-party data controllers for the purposes described in our Privacy Policy.  We will only provide your Personal Data to third-party data controllers where you have not opted-out of such disclosures, or in the case of sensitive Personal Data, where you have opted-in if the Privacy Shield requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for Personal Data the Privacy Shield requires. We also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received. If we transfer your Personal Data to one of our affiliated entities within our corporate group, we will take steps to ensure that your Personal Data is protected with the same level of protection the Privacy Shield requires.

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.

Security

Storm 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.

Access Rights

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 Data Protection Manager: gdpr@stormmanagement.com. 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 ICDR Privacy Shield dispute resolution panel in the United States. If you are unsatisfied with the resolution of your complaint, you may contact https://www.icdr.org/privacyshieldfor further information and assistance. We will cooperate with ICDR pursuant to the ICDR International Mediation Rules, which are accessible on the ICDR website at https://www.icdr.org/. For residual complaints not fully or partially resolved by other means, you may be able to invoke binding arbitration as detailed in the Principles.

In compliance with the Privacy Shield Principles, Storm Management LLC commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Storm Management LLC at: gdpr@stormmanagement.com

Storm Management LLC has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.

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 Storm  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).

CONTACT US

If you have any questions about this Policy, please contact us via email at Data Protection Manager at GDPR@stormmanagement.com.

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