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Safe Harbor Data Privacy Policy

PARRON LAW Safe Harbor Data Privacy Policy

PARRON LAW respects individual privacy and values the confidence of its employees, shareholders, clients and business partners and others. PARRON LAW strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, and also follows client service best practice and principles at all times. This Safe Harbor Data Privacy Policy (the “Policy”) sets forth the privacy principles PARRON LAW follows with respect to transfers of personal information from the European Economic Area (EEA),which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway to the United States.

Safe Harbor

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “U.S.-EU Safe Harbor”). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). Consistent with its commitment to appropriately protect personal privacy, PARRON LAW adheres to the principles set forth in the U.S.-EU Safe Harbor.

Scope

This Safe Harbor Data Privacy Policy (the “Policy”) applies to all personal information received by PARRON LAW in the United States from the EEA, in any format, including electronic, paper or verbal.

Definitions

For purposes of this Policy, the following definitions shall apply:

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, PARRON LAW or to which PARRON LAW discloses personal information for use on PARRON LAW’s behalf.

“PARRON LAW” means Parron & Associates, PL dba PARRON LAW, its predecessors, successors, subsidiaries, affiliates and branch offices.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of PARRON LAW to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, PARRON LAW will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

The privacy principles in this Policy have been developed based on the Safe Harbor Principles.

NOTICE: Where PARRON LAW collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which PARRON LAW discloses that information, the choices and means, if any, PARRON LAW offers individuals for limiting the use and disclosure of personal information about them, and how to contact PARRON LAW. Notice will be provided in clear and conspicuous language when individuals in the EEA are first asked to provide personal information to PARRON LAW, or as soon as practicable thereafter, and in any event before PARRON LAW uses or discloses the information for a purpose other than that for which it was originally collected.

Where PARRON LAW receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: PARRON LAW will offer individuals in the EEA the opportunity to choose (opt-out) when  their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, PARRON LAW will give individuals in the EEA the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

PARRON LAW will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY: PARRON LAW will use personal information relating to individuals in the EEA only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. PARRON LAW will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS: PARRON LAW will obtain assurances from its agents that they will safeguard personal information relating to individuals in the EEA consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). Where PARRON LAW has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, PARRON LAW will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, PARRON LAW will grant individuals in the EEA reasonable access to personal information that it holds about them (except where the burden or expense of providing access would be disproportionate to the risk to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated). In addition, PARRON LAW will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY: PARRON LAW will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

TRAINING & ENFORCEMENT: PARRON LAW confidentiality, security, data handling (information sensitivity) and privacy policies that govern all data and information disclosed to PARRON LAW attorneys, staff, and Agents.  All personnel are made aware of these policies through regular publication of the policies and by regular training.  PARRON LAW will conduct compliance audits of its relevant privacy practices to verify adherence to this and other policies. Any employee that PARRON LAW determines is in violation of these policies will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION

Any questions or concerns regarding the use or disclosure of personal information should be directed to the PARRON LAW Privacy Office at the address given below. PARRON LAW will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy.

For unresolved complaints related to PARRON LAW human resources data, PARRON LAW will cooperate with the European Data Protection Authorities (DPA’s).

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by the Firm’s U.S. offices to the Principles (and this Policy) may be limited (a) to the extent necessary to meet national security, public interest, or law enforcement requirements; (b) by statute, government regulation, or case law that create conflicting obligations or explicit authorization, provided that, in exercising any such authorization, our non-adherence is limited to the extent necessary to meet the overriding legitimate interests we further; or (c) if the effect of the EU Directive on Data Protection (the “Directive”) or EU Member State Law is to allow exceptions or derogations, provided we apply such exceptions or derogations in comparable contexts.  Where the options is allowable under the Principals and/or U.S. law, we will opt for the higher protection where reasonably possible.

CONTACT INFORMATION

Questions for comments regarding this Policy should be submitted to the PARRON LAW Privacy Department by mail to:

PARRON LAW
Attn: Privacy Department

175 SW 7th Street, Suite 1210
Miami, FL 33130
United States

Or by email to info@ParronLaw.com.

AMENDMENTS

This policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principals.  A notification will be posted on the PARRON LAW website (www.PARRONLAW.com) prior to any changes being made that will have a material impact on this policy.

To learn more about the Safe Harbor program, and to view PARRON LAW’s certification, please visit www.export.gov/safeharbor/