As set forth in Great Elm Solutions Code of Conduct: “We fully respect the confidentiality and privacy of our clients, our people and all with whom we do business.”
Great Elm Solutions, Inc., (“Great Elm Solutions,” “we,” “us,” or “our”) complies with the requirements of, and is application pending for the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce (the “Principles”). Great Elm Solutions has certified that it adheres to the Principles with respect to personal information (as described below) that is transferred from the European Union and its Member States, the European Economic Area, the United Kingdom and/or Switzerland (“EU”) to the United States. If there is any conflict between the terms in this Policy and the Principles, the Principles shall govern. Great Elm Solutions U.S. is subject to investigatory and enforcement powers of the U.S. Federal Trade Commission.
This Policy applies to personal information within the scope of Great Elm Solutions policies, which covers the following categories of information:
· Personal information regarding current, former and prospective partners, principals and employees for the purposes of operating and managing Great Elm Solutions, performing human resource administration and maintaining contact with individuals.
· Personal information regarding current, former and prospective clients and their personnel or others for the purposes of delivering Great Elm Solutions services, maintaining ongoing relationships and performing business development activities.
· Personal information regarding our third parties (e.g., vendors, service providers, etc.) and their personnel for the purposes of managing and administering Great Elm Solutions business relationships with such third parties.
· Additionally, Great Elm Solutions may, from time to time, collect personal information from the general public in order to answer inquiries or provide information requested.
For the purposes of this Policy, “personal information” means information that is about, or pertains to a specific individual and can be linked either directly or indirectly to that individual. In addition, certain personal information covered by Great Elm Solutions Policy may be subject to more specific privacy policies of Great Elm Solutions.
· Certain Great Elm Solutions websites maintain their own privacy policies that apply to personal information collected via those sites. These policies may be accessed through those websites.
· Personal information obtained from or relating to clients or former clients is further subject to the terms of any specific privacy notice provided to the client, any contractual arrangements with the client and applicable laws and professional standards.
Individual Notice and Choice
We collect and process personal information from certain individuals and for the purposes described in this Policy. Personal information covered by this Policy is collected and processed only as permitted.
Disclosures & Accountability for Onward Transfers
Consistent with its Policy, Great Elm Solutions may transfer personal information to third parties, including transfers from one country to another. We will only disclose an individual’s non-public personal information to third parties under one or more of the following conditions:
· The disclosure is to a third-party providing services to Great Elm Solutions, or to the individual, in connection with the operation of our business, and as consistent with the purpose for which the personal information was collected. We maintain written contracts with these third parties and require that these third-parties provide at least the same level of privacy protection and security as required by the Principles. To the extent provided by the Policy, Great Elm Solutions remains responsible and liable if a third-party that it engages to process personal information on its behalf does so in a manner inconsistent with the Policy, unless Great Elm Solutions proves that it is not responsible for the matter giving rise to the damage;
· With the individual’s permission to make the disclosure;
· Where required to the extent necessary to meet a legal obligation to which Great Elm Solutions is subject, including a lawful request by public authorities and national security or law enforcement obligations and applicable law, rule, order, or regulation.
· Where reasonably necessary for compliance or regulatory purposes, or for the establishment of legal claims.
Individuals whose personal information is covered by this Policy have the right to access the personal information that Great Elm Solutions maintains. Individuals may contact us to correct, amend or delete such personal information if it is inaccurate or has been processed in violation of the Policy (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated). Requests for access, correction, amendment or deletion should be sent to: finance@Greatelm.com.
Great Elm Solutions takes appropriate measures to protect personal information in its possession to ensure a level of security appropriate to the risk of loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures take into account the nature of the personal information and the risks involved in its processing, as well as best practices in the industry for security and data protection.
Data Integrity and Purpose Limitation
Great Elm Solutions collects and processes personal information only to the extent that it is compatible with the purposes for which it was collected or subsequently authorized by the data subject. Great Elm Solutions does not retain personal information after it no longer serves the purposes for which it was collected or subsequently authorized. Great Elm Solutions takes reasonable steps to ensure that personal information is accurate, complete, current, and reliable for its intended use.
In compliance with the Policy, Great Elm Solutions commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Policy should first contact Great Elm Solutions at: finance@Greatelm.com . Great Elm Solutions has a policy of responding to individuals within forty-five (45) days of an inquiry or complaint.
Great Elm Solutions may update this Policy at any time.
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