CLIENT PRIVACY POLICY

Sudio Advisory respects your concerns about privacy; it participates in the EU-U.S. and Swiss-U.S. Privacy Shield frameworks (collectively, the “Privacy Shield”) issued by the U.S. Department of Commerce.  Sudio Advisory recognizes that the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield are no longer valid transfer mechanisms for personal information from the European Union and its Member States, the European Economic Area, or Switzerland. The U.S. Department of Commerce has stated that it will nonetheless continue to administer the Privacy Shield program and that participants are not relieved of their obligations under the Privacy Shield. Accordingly, Sudio Advisory, as a participant in the Privacy Shield program, will continue to comply with its commitments under the Privacy Shield (as described more fully below) and its robust internal data protection policies. Please also see our Website Privacy Policy for more information on how we protect personal information in accordance with applicable legal requirements, including the European Commission approved standard contractual clauses.

 

For purposes of this Policy:

Sudio Advisory” means the subsidiaries and affiliates of Sudio Advisory.

“Client” means any entity that obtains strategic and management consulting or other services from the Sudio Advisory.

“Consumer” means any natural person who is located in the EU or Switzerland, but excludes any individual acting in his or her capacity as a Worker.

“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“EU” means the European Union and Iceland, Liechtenstein and Norway.

“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by Sudio Advisory in the U.S. from the EU or Switzerland, and (iii) recorded in any form.

“Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield.

“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.

“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (including trade union-related views or activities), sex life (including personal sexuality), information on social security measures, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings (including administrative proceedings and criminal sanctions).

“Worker” means any current, former, or prospective employee of the Sudio Advisory, who is located in the EU or Switzerland.  For purposes of this Policy, “Worker” includes any managing director, temporary worker, intern, other non-permanent employee, contractor, or consultant of Sudio Advisory, who is located in the EU or Switzerland.

Sudio Advisory’s Privacy Shield certification, along with additional information about the Privacy Shield principles, can be found here.  For more information about Sudio Advisory’s processing of Personal Data obtained from Consumers on Sudio Advisory’s websites and mobile applications, please visit Sudio Advisory’s Website Privacy Policy.

Types of Personal Data Sudio Advisory Collects

As a Processor, Sudio Advisory receives Personal Data about its Clients’ Consumers located in the EU and Switzerland. For example, in connection with providing strategic and management consulting or other services to its Clients, Sudio Advisory may access or obtain Personal Data about a Client’s Consumers located in the EU and Switzerland. In addition, Sudio Advisory may access or obtain Personal Data about a Client’s Consumers located in the EU and Switzerland in connection with providing support services to the Sudio Advisory Group, including during the course of providing (i) data storage, website and application hosting and maintenance, email, telephony and network connectivity, and other information technology infrastructure and services; (ii) data back-up and restoration, disaster recovery and business continuity planning and (iii) other technical, organizational, and administrative functions and resources.

Sudio Advisory also collects Personal Data directly from Consumers. This collection occurs, for example, when a Consumer visits Sudio Advisory’s websites or mobile applications, and provides Personal Data through the websites or mobile applications. In addition, Sudio Advisory obtains Personal Data, such as contact information, in connection with maintaining the firm’s Client relationships and providing services to Clients. Sudio Advisory also obtains Personal Data, such as contact information, of its vendors’ representatives. Sudio Advisory uses this information to manage its relationships with its vendors.

Sudio Advisory’s privacy practices regarding the processing of Consumer Personal Data comply, as appropriate, with the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.

 

Notice

Sudio Advisory provides information in this Policy and the company’s Website Privacy Policy about its Consumer Personal Data practices, including the types of Personal Data Sudio Advisory collects, the types of third parties to which Sudio Advisory discloses the Personal Data and the purposes for doing so, the rights and choices Consumers have for limiting the use and disclosure of their Personal Data, and how to contact Sudio Advisory about its practices concerning Personal Data.

When Sudio Advisory acts as a Processor and Consumer Personal Data is transferred to Sudio Advisory in the U.S. on behalf of a Client, the Client is responsible for providing appropriate notice to its Consumers and obtaining the requisite consent.

Relevant information also may be found in privacy notices pertaining to specific data processing activities.

 

Choice

When Sudio Advisory collects Personal Data directly from Consumers, the company generally offers those Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the Privacy Shield Principles, Sudio Advisory obtains opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact Sudio Advisory as indicated below regarding the company’s use or disclosure of their Personal Data. Unless Sudio Advisory offers Consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy or the company’s Website Privacy Policy.

When Sudio Advisory maintains Personal Data about Consumers with whom Sudio Advisory does not have a direct relationship because Sudio Advisory obtained or maintains the Consumers’ data as a Processor, Sudio Advisory’s Clients are responsible for providing the relevant Consumers with certain choices with respect to the Clients’ use or disclosure of the Consumers’ Personal Data.

Sudio Advisory shares Consumer Personal Data with its affiliates and subsidiaries. Sudio Advisory may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data, (i) to third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements.  Sudio Advisory also reserves the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

 

Accountability for Onward Transfer of Personal Data

This Policy and Sudio Advisory’s Website Privacy Policy describe Sudio Advisory’s sharing of Consumer Personal Data.

To the extent Sudio Advisory acts as a Controller, except as permitted or required by applicable law, Sudio Advisory provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers.  Sudio Advisory requires third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and (iii) notify Sudio Advisory and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Privacy Shield Principles.

With respect to transfers of Consumer Personal Data to third-party Processors, Sudio Advisory (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the Privacy Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Sudio Advisory’s obligations under the Privacy Shield Principles, (v) requires the Processor to notify Sudio Advisory if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request.  Sudio Advisory remains liable under the Privacy Shield Principles if the company’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Sudio Advisory proves that it is not responsible for the event giving rise to the damage.

 

Security

Sudio Advisory takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

 

Data Integrity and Purpose Limitation

Sudio Advisory limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing.  Sudio Advisory does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer.  In addition, to the extent necessary for these purposes and consistent with its role as a Controller or Processor, Sudio Advisory takes reasonable steps to ensure that the Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current.  In this regard, Sudio Advisory relies on its Consumers and Clients (with respect to Personal Data of Consumers with whom Sudio Advisory does not have a direct relationship) to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized.  Consumers (and Clients, as appropriate) may contact Sudio Advisory as indicated below to request that Sudio Advisory update or correct relevant Personal Data.