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Privacy Shield Policy

UnitedLex Corporation (“UnitedLex”) strives to collect, use and disclose personal information (defined below) in a manner consistent with the laws of the countries in which it does business. UnitedLex, in its role as a data processor and provider of litigation support and other consulting services, may receive personal information of individuals residing in the European Union (“EU”) or Switzerland when it does business with data controller-clients that possess personal information.  UnitedLex abides by contractual obligations it has in place with data controller-clients, including those that apply to data processing and transfer. In addition, UnitedLex is a participant in the Privacy Shield program entered into between the EU Commission and U.S. Department of Commerce (the “Department”), as well as the Swiss-U.S. Privacy Shield (hereinafter collectively referred to as “Privacy Shield”).  A list of Privacy Shield participants may be accessed at the following link. As a Privacy Shield participant, UnitedLex is committed to protecting personal information in accordance with this Policy and the principles described in the Privacy Shield. 

DEFINITIONS

“UnitedLex Corporation” is a United States corporation incorporated in the state of Delaware with its principal base of business at 6130 Sprint Parkway, Suite 300, Overland Park, KS. UnitedLex Corporation operates multiple facilities throughout the United States.

"Personal information" shall mean any information relating to an identified or identifiable natural person residing in the European Union or Switzerland. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

“Sensitive information” shall be mean any personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual. This includes data that UnitedLex receives from a third party that the third party identifies and treats as sensitive.

“Data controller” shall mean a natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes, conditions and means of processing of personal information.

“Data processor” shall mean a natural or legal person or other body which processes personal information on behalf of a data controller. 

NOTICE

UnitedLex does not independently collect personal information in its role as a data processor and provider of litigation support and other consulting services. Instead, UnitedLex may receive, or be directed to collect, personal information from data controller-clients in connection with UnitedLex’s provision of litigation support other consulting services to those data controller-clients. In such instances, UnitedLex acts at the direction of the data controller-client, provided that such directions are not inconsistent with the Privacy Shield principles or other applicable law, regulation or corporate policy.

In the limited situations where UnitedLex does independently collect personal information as a data controller, it shall inform individuals about: (a) the purposes for which it collects and uses personal information about them; (b) the individuals’ right to access their personal information; (c) the types or identities third parties to which UnitedLex discloses personal information and the purposes for such disclosure; (d) and the choices and means UnitedLex offers individuals for limiting the use and disclosure of their personal information; (e) that UnitedLex may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information, or as soon as practicable thereafter, and in any event before UnitedLex uses the information for a purpose other than that for which it was originally collected.

CHOICE

UnitedLex does not independently collect personal information in its role as a data processor and provider of litigation support and other consulting services. UnitedLex will work in good faith with individuals whose personal information it receives under the Privacy Shield that are interested in exercising their right to choose whether their personal information (a) will be disclosed to a third party or (b) used for a purpose that is materially different – or in the case of sensitive information, different – than the purpose for which the personal information was originally collected or subsequently authorized. This may include UnitedLex facilitating communication between the individual and data controller-client from which UnitedLex received the personal information or sensitive information in question.

In the limited situations where UnitedLex does independently collect personal information as a data controller, including but not limited to employment-related activities, it will offer individuals the opportunity to choose (specifically, opt out of) whether 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  information, UnitedLex will give individuals the opportunity to affirmatively and explicitly provide consent (specifically, opt in) to (a) the disclosure of the information to a third party or (b) the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. UnitedLex will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise. Questions regarding this section should be directed to the contact listed below.

DATA INTEGRITY AND PURPOSE LIMITATION

In its role as a data processor and provider of litigation support and other consulting services, UnitedLex will use personal information only in ways that are compatible with the purposes for which it was received from the data controller-client. To the extent necessary for those purposes, UnitedLex will take reasonable steps to ensure that personal information is reliable for its intended use, accurate, complete, and current. UnitedLex shall adhere to the Privacy Shield principles for as long as it retains such personal information. UnitedLex shall not retain personal information received from data controller-clients for longer than is necessary to achieve the purposes for which the personal information was received.

In the event UnitedLex independently collects personal information as a data controller, it shall limit personal information it collects to what is relevant for purposes of the processing. Additionally, it shall not process personal information in ways that are incompatible with the purpose for which it has been collected or subsequently authorized by the individual. To the extent necessary for those purposes, UnitedLex shall take reasonable steps to ensure that the personal information is reliable for its intended use, accurate, complete and current. UnitedLex shall adhere to the Privacy Shield principles for as long as it retains such personal information. UnitedLex shall not retain personal information for longer than is necessary to achieve the purposes for which the personal information was collected or subsequently authorized by the individual. 

ONWARD TRANSFER

In its role as a data processor and provider of litigation support and other consulting services, UnitedLex does not transfer personal information it receives under the Privacy Shield to third parties so that the third parties may act as a controller of the personal information.

Additionally, in its role as a data controller, UnitedLex does not generally transfer personal information it receives under the Privacy Shield to third parties acting as agents of UnitedLex. However, in the event UnitedLex does transfer personal information it receives under the Privacy Shield to third parties acting as agents of UnitedLex, UnitedLex shall: (a) transfer such personal information only for limited and specified purposes, (b) ascertain that the third party agent is obligated to provide at least the same level of privacy protection as is required by the Privacy Shield principles, (c) take reasonable and appropriate steps to ensure that the third party agent effectively processes the personal information transferred in a manner consistent with UnitedLex’s obligations under the Privacy Shield principles, (d) require the third party agent to notify UnitedLex if it makes a determination that it can no longer meet its obligation to provide the same of level of protection as required by the Privacy Shield principles, (e) upon notice, including under point (d) abpve, take reasonable and appropriate steps to stop and remediate unauthorized processing, and (f) provide a summary or a representative copy of the relevant privacy provisions of its contract with that third party agent to the Department upon request.

UnitedLex shall be liable under the Privacy Shield if it transfers personal information received under the Privacy Shield to a third party and such third party processes the personal information in a manner inconsistent with the Privacy Shield principles, provided that UnitedLex shall not be liable if it can prove it was not responsible for the event giving rise to the applicable damage. 

SECURITY

UnitedLex will take reasonable and appropriate measures to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. UnitedLex limits access to personal information and data to those persons in the UnitedLex organization, or agents of UnitedLex, that have a specific business purpose for maintaining and processing such information and data. 

ACCESS

As stated throughout this Policy, UnitedLex does not independently collect personal information in its role as a data processor and provider of litigation support and other consulting services. UnitedLex will work in good faith with individuals whose personal information it receives under the Privacy Shield that are interested in exercising their right of access under the Privacy Shield or applicable data privacy law. This may include UnitedLex facilitating communication between the individual and data controller-client from which UnitedLex received the personal information in question.

In the limited situations where UnitedLex independently collects personal information as a data controller, including but not limited to employment-related activities, upon request, UnitedLex will grant individuals reasonable access to the personal information that it holds about them. In addition, UnitedLex shall allow individuals to correct, amend, or delete information that is inaccurate or has been processed in violation of the Privacy Shield principles. UnitedLex reserves the right to deny access or limit access in cases where the burden or cost of providing access would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated.

ENFORCEMENT

Individuals who wish to file a complaint or who take issue with this Policy should direct such communication to the contact below. Filing a complaint in English will expedite the process. UnitedLex will in good faith investigate and attempt to resolve complaints and disputes in accordance with the principles contained in this Policy. UnitedLex shall respond to all complaints within 45 days of receipt. Individuals also have the option of filing a complaint with JAMS, an independent dispute resolution body located in the United States. UnitedLex has designated JAMS as its independent dispute resolution body, and UnitedLex shall be solely responsible for all costs associated with any complaints filed with JAMS that regard UnitedLex’s violation of this Policy. Information about filing a complaint with JAMS can be found at its website: www.jamsadr.com.  UnitedLex acknowledges that under certain circumstances and subject to the conditions of Annex I of the Privacy Shield program, it may be required to participate in binding arbitration to resolve residual claims by individuals.

UnitedLex affirms that it is subject to the regulatory powers of the Department) and Federal Trade Commission (“FTC”), among other governmental bodies with jurisdiction over UnitedLex. If UnitedLex becomes subject to an FTC or court order based on non-compliance with the Privacy Shield, it shall make public any relevant Privacy Shield-related sections of any compliance or assessment report submitted to the FTC, to the extent such disclosure does not violate applicable confidentiality obligations.

UnitedLex also affirms that the statements made about its data privacy practices are true, and that it has established procedures to ensure that such practices are implemented as presented. A statement verifying UnitedLex’s self-assessment is available upon written request. Should UnitedLex discover that it is not in compliance with the Privacy Shield principles or the privacy practices described in this Policy, it shall remediate the instances of non-compliance and take appropriate steps to ensure such non-compliance does not reoccur. 

CONTACT

Interested individuals are encouraged to contact UnitedLex with questions, complaints, access requests and any other issue arising under the Privacy Shield. Requests can be directed to:

Jason Straight
Senior Vice President, Chief Privacy Officer – Cyber Risk Solutions
100 Broadway, 22 Fl
New York, NY 10005 
jason.straight@unitedlex.com