OUR COMMITMENT TO PRIVACY
Innovative Discovery places the highest value on ensuring the security of all data entrusted to us. We respect individual privacy rights and adhere to established internal protocols to ensure that our security and privacy practices and procedures comply with both US and international law.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Innovative Discovery is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. For the purposes of this policy, personal data is defined as any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified (directly or indirectly) by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.
1. INFORMATION ABOUT INNOVATIVE DISCOVERY
This policy is designed to provide information regarding Innovative Discovery’s collection and processing of personal data through your use of our websites and hosted software platforms.
Attention: Innovative Discovery Privacy Officer
Wezembeekstraat 2 bus 1
1930 Zaventem, Belgium
In the United States, or anywhere else:
Innovative Discovery, LLC
Attention: Privacy Officer
1700 North Moore St, Suite 1500
Arlington, VA 22209
2. INFORMATION INNOVATIVE DISCOVERY COLLECTS ABOUT VISITORS TO ITS WEBSITE
When you visit our website, our server automatically collects some information created by your internet browser or computing device, which may constitute personal data, and can include, but is not limited to:
- IP address;
- date, time and duration of your visit;
- browser type;
- operating system;
- page visits;
- information from third parties;
- other information about your computer or device;
Information You Provide
By accessing portions of the website, conducting business with us or seeking to conduct business with us, you may be required to provide personal data:
- by filling in forms (for example, a “Contact Us” form) on our website or at a trade show or anywhere else we conduct business;
- by downloading documentation from our website;
- by subscribing to newsletters or other communications;
- by corresponding with us by phone, e-mail or otherwise using our contact details;
- by participating in Innovative Discovery webinars
Generally, the personal data you give Innovative Discovery may include name, business affiliation, business address, telephone number, and email address, and any details required to resolve any inquiries or complaints.
Personal data may also be required to enter into or perform under contract with Innovative Discovery.
Information From Other Sources
As an eDiscovery company, most of the data Innovative Discovery collects and stores is provided by clients, rather than directly from individuals. Therefore, Innovative Discovery typically has no direct relationship with the individuals whose personal data it processes. Any data received on behalf of our clients is used strictly for the business purposes defined in our agreements with our clients and is not shared with third parties without written consent from the data controllers of the data in question.
3. USE OF PERSONAL DATA.
The information below is a high-level overview of our reasons for using personal data. Further information regarding processing your personal information may be provided in a separate notice or contract.
Innovative Discovery processes personal information only in ways that are compatible with the purpose for which the data was collected or subsequently authorized by the individual. All processing and use of your personal data is justified by a “condition” for processing. Frequently, processing will be justified because:
- the processing is necessary to perform a contract with you or take steps to enter into a contract at your request
- the processing is necessary for us to comply with a legal obligation
- the processing is in Innovative Discovery’s legitimate interests, which are not superseded by your interests and rights. Innovative Discovery’s interests include using customer and website user data to conduct and develop our business activities while limiting the use of personal data to purposes that support the conduct and development of our business; or
- your consent to process your data.
We use the personal data we collect to conduct and develop our business with you and with others, as more fully described below:
- provide services you have contracted for;
- evaluate, improve and develop our products and services generally;
- provide documentation or communications upon request;
- correspond with users to resolve their questions or complaints;
- send marketing communications only where allowed by law;
- protect and ensure the safety of Innovative Discovery’s confidential and proprietary information, as well as its employees;
- protect against and investigate fraud, risk exposure, claims and other liabilities, including but not limited to violation of our contract terms or laws or regulations;
- In the event of a sale or transfer of assets related to an acquisition, merger, reorganization, sale or bankruptcy, Innovative Discovery will continue to ensure the confidentiality of any personal information. Innovative Discovery does reserve the right to make such disclosure as is required upon providing notice to the clients for whom such data is being held.
Innovative Discovery will not sell personal data to third parties.
4. DISCLOSURE OF PERSONAL DATA
Innovative Discovery will not disclose an individual’s personal data to any third party without the consent of our clients unless:
- The individual has consented, in writing, to the disclosure; and/or
- The disclosure is required by law or other professional standards; and/or
- The personal data is publicly available; and/or
- The disclosure is reasonably necessary for the establishment or defense of legal claims.
5. EU-U.S. AND SWISS-U.S. PRIVACY SHIELD
Innovative Discovery complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Innovative Discovery has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. Innovative Discovery agrees to offer individual citizens of the EU, EEA or Switzerland access to their personal data for purposes of correcting, amending or deleting inaccurate information unless the cost or burden of providing the access and/or changing or deleting the data proves unreasonable in view of the risk to the individual’s privacy. Innovative Discovery may determine the form of the disclosure and may charge a reasonable fee for resource use related to accessing, changing or deleting the personal information.
In compliance with the Privacy Shield Principles, Innovative Discovery 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 Innovative Discovery at:
Cathy Fetgatter, Senior Vice-President and Privacy Officer
Phone – 703-875-8003
Email – firstname.lastname@example.org
Innovative Discovery 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 data transferred from the EU and Switzerland.
Innovative Discovery operates in compliance with advice given by Data Protection Authorities, including remedial or compensatory measures for individuals affected by non-compliance. Innovative Discovery will provide the Data Protection Authorities with written confirmation that such corrective action has been taken, subject to the Company’s right to dispute the requested actions or remedial measures with the Federal Trade Commission.
The website and corresponding services are not intended for use by children under the age of 16 years and Innovative Discovery does not knowingly collect, store, share or use the personal data of children under this age. If you are under the age of 16 years, please do not provide any personal data, even if prompted by the website to do so. If you are under the age of 16 years and you have provided personal data, please ask your parent(s) or guardian(s) to notify Innovative Discovery immediately and it will promptly delete all such data.
7. MARKETING EMAILS
With your permission, and where legal, Innovative Discovery may communicate with you by email to tell you about its products and services. If you wish to opt-out of these communications, please use the “unsubscribe” link in our emails, or otherwise contact Innovative Discovery directly and we will discontinue these communications.
Innovative Discovery restricts access to information to Innovative Discovery employees who have a specific business purpose for collecting, maintaining, processing and/or reviewing data. Innovative Discovery regularly reviews our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to our systems. Innovative Discovery may disclose personal data to law enforcement officials in response to a lawful request made pursuant to national security interests or law enforcement requirements.
Innovative Discovery takes reasonable precautions to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Our security measures include physical, electronic, workflow and managerial protocols to safeguard and secure the personal data we collect and process.
9. RETENTION OF PERSONAL DATA
Innovative Discovery retains personal data only as long as required to fulfill the purposes for which it was collected. Innovative Discovery retains personal data for a specific period of time corresponding to a statute of limitation, for example to maintain an accurate record of your dealings with us.
However, Innovative Discovery may keep personal data for other periods of time, for instance when it is required to do so because of legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.
10. EXTERNAL LINKS
This website may contain links to third-party sites. Since Innovative Discovery does not control nor is responsible for the privacy practices of those websites, we suggest you review the privacy policies of these third-party sites. This notice applies solely to personal data collected by our websites or in the course of our business activities.
11. YOUR RIGHTS
Any individual who seeks access to, or who seeks to correct, amend or delete inaccurate data provided to Innovative Discovery by a client should contact Innovative Discovery’s client directly. If requested to remove data by our client, Innovative Discovery will respond within a reasonable timeframe.
You may also have the following rights:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of your personal data and to check that we are lawfully processing it.
- Request correction of your personal data. This enables you to have any incomplete or inaccurate data in our possession corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to request deletion or removal where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some limited cases, we may demonstrate that we have overriding legitimate grounds to process your information.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) you need us to hold the data – even if we no longer require it – as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
12. DISPUTE RESOLUTION
Additionally, an individual may, under certain conditions, invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved through the foregoing measures. Please visit the following link for more information. https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Cathy Fetgatter, Senior Vice-President and Privacy Officer
Phone – 703-875-8003
Email – email@example.com
This policy was last updated: May 25, 2018