clutch group – Global Legal Solutions


	Privacy Policy

	SAFE HARBOR DATA PRIVACY POLICY
	Clutch Group, LLC (“Clutch Group”) is a legal process outsourcing firm that provides document review, contract management, legal Research, compliance services and other legal support services. Clutch Group is strongly committed to protect personal privacy, and it 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 and the European Union. This statement applies to all personal information Clutch Group processes, including online, offline & 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 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
	Clutch Group adheres to the Safe Harbor Principles outlined in the Safe Harbor Agreement concerning the transfer of personal data from the European Union to the United States of America. The privacy principles mentioned in this policy are based on the Safe Harbor 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 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 910 17th Street N.W, Suite 800 Washington, DC 20006 clutchinfo@clutchgroup.com