Date: September 20, 2019
Modus eDiscovery Inc.’s participation in the Privacy Shield applies to all personal data that is received from the European Union, the United Kingdom and Switzerland. Modus will comply with the Privacy Shield Principles in respect of such personal data. Modus eDiscovery Inc. does not actively collect personal data from individuals, however may receive personal data from third parties in the normal course of providing eDiscovery services to parties involved in civil or criminal litigation, federal or state regulatory investigations or internal company investigations. The types of personal data received typically include names, addresses, email, network files (such as Microsoft Word, PowerPoint, Excel docs), and image files. None of the personal data Modus receives from third parties is used for company purposes by Modus, nor is any personal information disclosed to anyone outside of the respective litigation, regulatory or internal investigation for which the personal data was provided. If in the future, this practice changes, Modus will update this policy and provide individuals with choice regarding the sharing of their personal data with non-agent third parties. All data received by Modus, including personal data, must be preserved in its original state throughout eDiscovery processing. Modus acknowledges an individual’s right to access their personal data and would refer the individual to the third party who originally collected the individual’s personal data, for any correction, modification or deletion of their personal data. Notwithstanding, Modus may be required to disclose private data in response to a lawful request by a public authority, including for law enforcement or national security purposes.
In compliance with the Privacy Shield Principles, Modus eDiscovery, Inc. commits to resolve complaints about our collection or use of your personal information. European Union, United Kingdom or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Modus eDiscovery, Inc.’s Chief Technology Officer, John Crites via email at: firstname.lastname@example.org
Modus eDiscovery, Inc. has further committed to refer unresolved Privacy Shield complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. The services of the BBB EU Privacy Shield are provided at no cost to the individual.
As further explained in the Privacy Shield Principles, an individual has the option, under certain conditions, to invoke binding arbitration for complaints not resolved by any of the other Privacy Shield mechanisms noted above. Click here for more detailed information on binding arbitration provisions: https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Human Resources Data: If your complaint is related to human resources data, Modus eDiscovery, Inc. commits to cooperate with the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC), and comply with the advice given by the panel or Commissioner with regard to human resources data transferred from the EU or Switzerland, in the context of the employment relationship. Individuals wishing to identify and/or contact their specific data authority may go to the following links:
EU DPA’s for EU Individuals — https://edpb.europa.eu/about-edpb/board/members_en
UK ICO for UK Individuals — https://ico.org.uk/
Swiss FDPIC for Swiss Individuals — https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html