Privacy Policy | Clutch Group

Privacy Policy

Clutch Group, LLC (“Clutch Group”) is a legal process outsourcing firm that provides document review, contract management, compliance, legal research, and other legal support services. Clutch Group is strongly committed to protecting personal privacy, and abides by the Safe Harbor Principles of the United States Department of Commerce.

This Privacy Policy sets forth the privacy principles that Clutch Group follows with respect to the protection and transfer of personal information, recorded in any format, between the United States, the European Union and Switzerland. This statement applies to all personal information Clutch Group processes, including online, offline and HR-related data.

Definition

For purposes of this statement, “Personal Information” means any information or set of information that is transferred from the European Union or Switzerland to the United States, is recorded in any form, pertains to or is about any individual, and can be linked to or used to identify that individual. Personal information does not include information that is publicly available and pertains to or is about a specific individual, but from which that individual could not reasonably be identified.

Safe Harbor

Clutchgroup complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland.  Clutchgroup has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, please visit:http://export.gov/safeharbor/  (n.b., to view Clutchgroup certification, please seehttps://safeharbor.export.gov/list.aspx).

The privacy principles mentioned in this policy are based on the Safe Harbor Privacy Principles.

Notice & Choice

To the extent permitted in the Safe Harbor Agreement, Clutch Group reserves the right to process personal information in its capacity and role of providing document review, contract management, legal research, compliance services and other legal support services to our clients.

Disclosures & Transfers

  • We do not sell, rent or disclose to third parties any personal data derived from the services rendered for our clients, except when one or more of the following conditions are true:
  • Clutch Group has the individual’s permission to make the disclosure;
  • The disclosure is required by law or professional standards;
  • The disclosure is reasonably related to the sale or disposition of all or part of Clutch Group’s business;
  • The information in question is publicly available;
  • The disclosure is reasonably necessary for the establishment or defense of legal claims;
  • The disclosure is to another Clutch Group entity or to persons or entities providing services on Clutch Group’s or the individual’s behalf (each a “transferee”), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
    • is subject to laws providing an adequate level of privacy protection;
    • has agreed in writing to provide an adequate level of privacy protection; or
    • Subscribes to the Safe Harbor Principles.

Data Security & Integrity

To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of its clients, customers and business partners, Clutch Group has put in place and rigorously enforces appropriate physical, electronic, and managerial procedures to safeguard and secure the information that Clutch Group processes.

Enforcement

Clutch Group has put in place measures to ensure ongoing compliance with the Safe Harbor Principles. Clutch Group complies with Safe Harbor Principles through self certification. Clutch Group periodically verifies the accuracy of the policy, implementation and its conformity. Clutch Group encourages interested persons to raise any concerns about its implementation of this Privacy Policy using the contact information below. Clutch Group will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Privacy Policy.

Any claim that is unresolved by Clutch Group’s internal process alternatively will be resolved by cooperating with European Data Protection Authorities or Swiss Federal Data Protection and Information Commissioner (FDPIC) for further investigation.

Changes

Clutch Group may amend this Privacy Policy from time to time, consistent with the requirements of the Safe Harbor Principles. Clutch Group will publish the revised Privacy Policy at its respective locations.

Information Subject To Other Policies Or Standards

Clutch Group is committed to following the Safe Harbor Principles for all personal information within the scope of the Safe Harbor Agreement. Certain information, however, is subject to policies of Clutch Group that may differ in some respects from the provisions of this Privacy Policy. Information subject to such additional policies includes information obtained from or relating to a client, customer or business partner or former client, customer or business partner that is subject to the terms of any privacy notice to or agreement with such client, customer or business partner, any engagement letters with such client, customer or business partner, and applicable laws and professional standards.

Contact Information

Questions or comments regarding Clutch Group’s Safe Harbor certification and Privacy Policy should be submitted through the contact channels listed below:

Clutch Group, LLC

529 14th St NW

Suite 440

Washington, DC 20045

Email: contactus@clutchgroup.com

 

NOTICE:  Clutch Group does not provide legal advice or otherwise engage in the practice of law in any jurisdiction.