Privacy Policy

Strategic Insight Group Personal Information Privacy Policy/Notice

Who We Are

Strategic Research and Development LLC doing business as Strategic Insight Group (“SIG” “we” or “us”) is a private intelligence firm providing background/due diligence investigations and geopolitical risk consulting services to its business customers (“SIG
clients”) who are investors, companies, and law firms. SIG’s business services are designed to detect all possible elements that could lead to operational, reputational, or headline risk of SIG’s client and include collecting and reporting on sensitive and
confidential information about individuals such as background investigation reports on individual associates of prospective investments, employees of investment portfolio companies, and pre-employment screening and background verification of job
applicants.

This Privacy Policy covers the information practices of SIG and describes the principles SIG follows with regard to personal information submitted to SIG by our clients and individuals associated with potential investments and job applicants. It also covers other information that we collect from Third Parties and other sources in connection with the services we provide our clients. These information privacy principles have been implemented by all members of SIG’s workforce regardless of their location. 

What SIG Does

SIG’s primary clients are investors, ranging from institutional investors (“asset owners”) such as pension plans, to investment firms (“asset managers”) such as hedge funds and private equity firms, to family offices and high-net-worth individuals. SIG’s client services include investigating, from a non-financial standpoint only, potential investments (individuals or entities, and their associates or competitors); analyzing markets and political contexts; and performing pretransactional due diligence and post-transactional monitoring, including “indications and warnings” monitoring of industrial, political, regulatory, and security conditions, and other “enhanced due diligence” services not related to financial analysis.

SIG’s services for its public and private company clients (often portfolio or invested companies of investor clients) include providing market intelligence (market entry and expansion); competitor, customer, and consumer analysis; investigation of
potential partners or adversaries and their companies, including acquisition targets; anti-money-laundering and anti-corruption investigation; situational intelligence on problems; and political and regulatory intelligence.

SIG’s services for its law firm clients include litigation intelligence and asset discovery including establishing histories of persons and entities, links and connections, activity and behavioral patterns, strengths and vulnerabilities (collectively, the “SIG Services”)

Introduction

This website, www.sigintelligence.com, is owned by Strategic Insight Group (SIG). SIG is committed to being transparent about how it collects and uses the Personal Information of individuals and to meeting its data protection obligations. “Personal Information” means data that identifies or may be used to identify a specific individual.

From time to time, this Policy may be supplemented by communications from SIG’s Data Protection Officer. SIG workforce members, including third parties hired to carry out portions of the SIG Services (“Sub-contractors”) are expected to be familiar with and comply with this Policy/Notice. Failure to do so may result in disciplinary action up to and including termination.

Topics

General Provisions

  • Email Communications
  • Internet Cookies
  • California Privacy Rights
  • Other Websites and Social Media
  • LinkedIn and Job-Search Websites
  • Children
  • Security of Personal Information
  • Transfers of Personal Information to SIG Sub-Contractors and Other Third Party Service Providers
  • Business Transfers of Personal Information
  • How to Contact Us
  • Changes to this Privacy Policy

Provisions Applicable to Individuals in EU/EEA and Switzerland

  • EU/EEA Definitions
  • Notice to Individuals Located in the EU/EEA and Switzerland
  • EU/EEA/Swiss Personal Data SIG Collects
  • EU/EEA/Swiss Data Protection Principles & Best Practice Standards
  • EU/EEA/Swiss Personal Data Transfers to Independent Third Parties
  • How Long SIG Keeps EU/EEA/Swiss Personal Data
  • EU/EEA/Swiss Personal Data Rights including under the GDPR

Other EU/EEA and Swiss Provisions

  • International Transfers of Personal Data
  • EU-US and Swiss-US Privacy Shield

GENERAL PROVISIONS

Email Communications

SIG communicates with its Sub-contractors, clients, business partners and other people who have expressed interest in its services/products, through email. SIG protects its email address lists and other Personal Data used in email correspondence with  the same reasonable security practices it uses to protect all Personal Data it collects and processes. If you receive an email from SIG you are someone who has either:

1. Expressly shared your email address to receive information about SIG services/products (“opt-in”); or

2. Provided your email address to SIG through an existing relationship, including advertising.

SIG’s emails are sent with an automatic unsubscribe option if you would like to stop receiving emails from SIG. However, if you have a client or Sub-contractor account with us, we retain the right to contact you via email regarding the status of your account or other subjects related to transacting the SIG Services.

When we send emails, SIG sometimes tracks who has opened or clicked through the email contents. SIG tracks this information to measure interest in a subject, monitor an email campaign’s performance or better understand user trends so we can improve our
services/products.

SIG does not share, sell, or disclose your Personal Data to Third Parties for promotional use without your prior consent.

If you consent, SIG would like to send you information about SIG services/products that you may be interested in. If you have consented to receive marketing messages from SIG you may opt-out at any time.

Opt-out of SIG Marketing Emails

If you no longer want to be contacted by SIG about our products and services, please notify us at confidential.data@sigintelligence.com.

Because we plan our email communications in advance, it may take several weeks for your opt-out request to take effect. If you continue to receive marketing messages from SIG after you opt-out, please let us know so that we can investigate the situation.

Internet Cookies

Cookies are text files placed on your computer by websites to collect standard log information and visitor behavior information. SIG and its service providers use cookies on SIG’s website, www.sigintelligence.com. Information from cookies is used to track
visitor’s use on our website and to make statistical reports on activity on our website. For more information about cookies visit the website at www.aboutcookies.org or http://www.allaboutcookies.org/.

You can set your browser to reject cookies, and the above websites tell you how to remove cookies from your browser. In a few cases, some of SIG’s website features may not work when your browser does not accept cookies.

California Privacy Rights

If you live in California, California law allows you to request and obtain from SIG once a year, free of charge, a list of the third parties to whom we have disclosed your personal information (if any, and as defined under California law) for the third party’s direct marketing purposes in the prior calendar year, as well as the type of your personal information disclosed to those parties. If you live in California and would like to request this information, please send your request in an email to DPO@sigintelligence.com.

Other Websites and Social Media

Our website may contain links to other websites. This Privacy Policy only applies to SIG’s website so when you visit or use other websites you should read their own privacy policies. 

Our website and communications may contain links to the Twitter social media website, www.twitter.com. Social media sites and features may collect and use Personal Information from you. We have no control over and are not responsible for the privacy practices, policies, or content of any social media websites or features, even if you link to them from, or use them, on SIG’s website. Please review Twitter’s privacy policy at https://twitter.com/privacy.

We are not responsible for information, content, and/or the privacy practices of third parties operating websites that may link to this website. The inclusion of a link on this website does not imply endorsement by SIG of the linked site by us or our business partners.

LinkedIn and Job-Search Websites

You can apply for a job at SIG using LinkedIn and other job search websites. Those websites will verify your identity, give you the option to share personal information (such as your name and email address) with us, and auto-fill our job application signup form.

Children

The website is not intended for use by children under the age of 16, and there is no assumption that children will be using these website services at any time. If SIG becomes aware that a child has submitted Personal Information on the website, we will
immediately delete the information from our records.

Security of Personal Information

SIG takes the security of Personal Information seriously. SIG has internal policies and controls in place to protect Personal Information against loss, accidental destruction, misuse or disclosure, and to ensure that Personal Information is not accessed, except by SIG employees and Sub-contractors in the proper performance of their duties.

SIG maintains appropriate organizational, administrative, physical and technical safeguards including encryption, resilience of processing systems and backing up Personal Information for protection of the security, confidentiality and integrity of its
Personal Information. However, no Internet, email, or other electronic transmission is ever 100% secure or error free, so SIG cannot guarantee that your Personal Information will never be accessed, used, or disclosed, so you should take special care in deciding
what information you share with SIG.

“Phishing" is a scam designed to steal your Personal Information. If you receive an email that looks like it is from SIG asking you for information about you, please contact us.

SIG regularly monitors compliance with these safeguards and will not materially decrease the overall security of its Personal Information and SIG is not responsible for any damages or liabilities relating to any such incidents if caused by factors outside its reasonable control to the extent permitted by law. If there is a data breach, SIG will give notice of any loss, misuse, or alteration of Personal Information to affected individuals as required by applicable laws.

Transfers of Personal Information to SIG Sub-Contractors and Other Third Party Service Providers

SIG discloses Personal Information to SIG Sub-contractors where such Sub-contractors need to process or use that Personal Information in order to carry out portions of the SIG Services for our clients.

SIG hires other companies to perform certain business-related functions. Examples include maintaining our website and processing payments, marketing and advertising, marketing research and analysis, and customer service. When SIG transfers Personal Information to a Sub-contractor or other third party service provider, SIG only provides them with the Personal Information they need to perform their specific function under obligations of confidentiality and security as set forth in this Privacy Policy, and we do not authorize these service providers to use or disclose Personal Information except as necessary to perform the tasks we have asked them to do for us or to comply with legal requirements.

SIG also uses the services of publicly available databases located in the United States to process Personal Information including: LexisNexis; PACER; Bridger; The Work Number; and National Student Clearinghouse among others. 

Business Transfers of Personal Information

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, Personal Information may be part of the transferred assets, but in such case, we will use reasonable efforts to ensure that any such Personal Information will be handled by a buyer of our assets or business in accordance with the terms of this Privacy Policy.

How to Contact Us

Please contact us if you have any questions about SIG’s Privacy Policy/Notice or our information practices email SIG at DPO@sigintelligence.com or write to us at:

Strategic Insight Group
Data Protection Officer
6777 Camp Bowie Blvd
Suite 100
Fort Worth, Texas 76116

or call us at +1-817-999-6667

Changes to This Privacy Policy

We keep this Privacy Policy/Notice under regular review, and we will provide notice of any changes to it in accordance with applicable law. Please review this policy periodically, and especially before you provide any Personal Information to us. We will
also place any updates on our website. This privacy policy was last updated on July 2, 2018.

PROVISIONS APPLICABLE TO INDIVIDUALS LOCATED IN THE EU/EEA AND SWITZERLAND

The provisions of this Privacy Policy below are applicable between SIG and individuals located in the EU/EEA and Switzerland.

EU/EEA Definitions

'Consent’ or ‘Agree’ means your freely given, specific, informed and unambiguous expression of your wishes through a statement or other clear affirmative action such as checking a box or signing a consent form which indicates your agreement to SIG’s Processing of personal data relating to you.

‘Criminal Records Data’ means information about an individual's criminal convictions and offences, and information relating to criminal allegations and proceedings.

'Personal Data' means any Personal Information relating to you from which you can be identified, directly or indirectly, including name, identification number, location, online identifier such as your IP address or device ID, or one or more factors specific to physical, physiological, genetic, mental, economic, cultural or social identity. It includes any personal information whether it is held in paper, electronic or any other format.

‘Process or Processing’ means any use of Personal Data including collecting, recording, organizing, structuring, storing, adapting or altering, amending, retrieving, consulting, sharing, disclosing, making available, aligning or combining, restricting, transferring
outside the EU/EEA or erasing or destroying it.

‘Special Categories of Personal Data’ means Personal Data about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, ideological views or activities, information on social security measures, trade union membership, health, sex life, sexual orientation and biometric data, or any past administrative or criminal proceedings and sanctions.

'Third Party' includes our business partners and service providers who we authorize to
process your Personal Data or other information to help us with the activities described
in this Privacy Policy. It may include government bodies and public agencies and
authorities.

Notice to Individuals Located in the EU/EEA and Switzerland

SIG has appointed a Data Protection Officer (DPO) as the person with responsibility for SIG’s EU/EEA and Swiss data protection compliance. Our DPO can be contacted at [DPO@sigintelligence.com]. Questions about this policy, or requests for further
information, should be directed to our DPO.

If you are located in the EU/EEA or Switzerland and SIG’s business client (the data “controller” under applicable laws) is using the SIG Services to Process your Personal Data, you may contact SIG’s business client to object, restrict, access, correct, transfer
(data portability) or delete your Personal Data. If you need help finding contact information for a SIG business client’s privacy office, please contact us at DPO@sigintelligence.com.

EU/EEA/Swiss Personal Data SIG Collects

Personal Data SIG collects includes current, past and prospective employment information in the context of an employment or prospective employment relationship with a SIG business client. It includes any information that relates to a member or
prospective member of a SIG client’s workforce who can be identified from that information whether it is held in paper, electronic or any other format, including:

  • Identification data such as name, home address, personal telephone number, personal e-mail address, date of birth, social security number, national insurance number, photograph, marital /dependent status, and emergency contact information;
  • Information concerning employment such as salary, work and compensation history, planned salary, earnings, paid time off, salary grade, performance information (including performance appraisal, performance and attendance records), decisions to offer employment, CVs/Resumes, employment applications, employment references and background verification information;
  • Financial information such as credit reports, bank account numbers, tax-related information, and salary-related information;
  • Benefits plan information such as details of any dependents, beneficiaries, or other individuals;
  • Past administrative or criminal proceedings and sanctions.
  • If disclosed to SIG by the individual subject of investigation or discoverable by SIG in open source media: Special Categories of personal data including ethnic origin; political opinions; religion or religious or philosophical beliefs; trade union membership; heath related data; sexual orientation and/or sex life.
  • Other Information necessary for SIG’s business purposes which may be voluntarily disclosed to SIG by an individual subject of investigation in relation to a SIG background investigation.

EU/EEA/Swiss Data Protection Principles & Best Practice Standards

SIG Processes EU/EEA and Swiss Personal Data in accordance with the following data protection principles and intelligence industry best practice standards:

  • SIG Processes Personal Data lawfully, fairly and in a transparent manner consistent with applicable law, and its obligations to its clients.
  • SIG collects Personal Data only for specified, explicit and legitimate purposes consistent with applicable law, and its obligations to its clients.
  • SIG Processes Personal Data only where it is adequate, relevant and limited to what is necessary for the purposes of Processing consistent with applicable law, and its obligations to its clients.
  • SIG keeps accurate Personal Data and takes all reasonable steps to ensure that inaccurate Personal Data is rectified or deleted without delay consistent applicable law and its obligations to its clients.
  • SIG keeps Personal Data only for the period necessary for Processing consistent applicable law and its obligations to its clients.
  • SIG adopts appropriate measures to make sure that Personal Data is secure, and protected against unauthorized or unlawful processing, and accidental loss, destruction or damage.

SIG and/or its client tells individuals located in the EU/EEA and Switzerland the reasons for Processing their Personal Data, how it uses their Personal Data and the legal basis for Processing by providing them this Privacy Policy/Notice and related notices,
disclosures, and consent forms. SIG will not process Personal Data for other reasons.

Where applicable, individuals will be given the choice to Consent to having their Personal Data collected by way of a disclosure and consent form provided to them by SIG’s client prior to SIG beginning a background investigation. Individuals can decline to
sign the disclosure form, thereby stating they do not give their Consent to have their Personal Data collected or used. By Consenting to a background investigation report, and submitting information to our client, the individual is Agreeing to allow SIG to disclose Personal Data and other information about them to our client and to our sharing that information with our Sub-contractors. However, there may be circumstances under which SIG is permitted or even required to collect and process Personal Data without obtaining the individual’s consent, for example for the purposes of preventing money-laundering or fraud.

In any event SIG takes appropriate steps to ensure that Personal Data in its possession is accurate, complete, and current consistent with applicable law and intelligence industry best practice standards. However, all individuals in the EU/EEA or Switzerland are asked to inform SIG’s relevant client immediately about any changes in their Personal Data.

SIG will not Process Personal Data that qualifies as Special Categories of Personal Data for purposes incompatible with those described in this Policy unless the Processing is:

  • (a) permitted by applicable UK, EU/EEA or Swiss law;
  • (b) necessary for administering justice or for exercising statutory, governmental, or other public functions;
  • (c) necessary for the establishment of legal claims or defenses;
  • (d) in the vital interests of an individual in in the EU/EEA or Switzerland or another person;
  • (e) required to provide medical care or diagnosis; or
  • (f) necessary to carry out SIG’s legal obligations under applicable law.

Where SIG processes Special Categories of Personal Data or Criminal Records data to meet its obligations to its clients, this is done in accordance with a policy on Special Categories of Personal Data and Criminal Records data.

EU/EEA/Swiss Personal Data Transfers to Independent Third Parties

SIG will disclose Personal Data to Third Parties other than those identified above only if:

  • required by law or legal process (e.g., lawful requests by public authorities, including disclosures to law enforcement authorities in connection with their duties or to meet national security requirements);
  • to investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law.
  • to protect and defend the legal rights, property/or and legitimate interests of SIG and/or members of its workforce, clients, business partners, Sub-contractors and/or Third Parties; or
  • where necessary for SIG to perform a contractual obligation owed to a client, member of its workforce or for other lawful purposes.

How Long SIG Keeps EU/EEA/Swiss Personal Data

SIG will hold Personal Data

  • for the duration legally required or permitted by applicable law; and
  • as long as it is necessary to comply with SIG’s legal obligations or to resolve disputes and/or enforce our agreements.

EU/EEA/Swiss Personal Data Rights including under the GDPR

Individuals in the EU/EEA and Switzerland have a number of rights in relation to their Personal Data. SIG will maintain a program to ensure compliance with this Privacy Policy. All SIG workforce members whose responsibilities include the Processing of
EU/EEA/Swiss Personal Data are required to adhere to this Policy and any implementing policies. Failure to do so is deemed a serious offence, for which disciplinary action may be taken, potentially resulting in termination of employment. Equally, the misuse of Personal Data by an individual or organization acting as a Subcontractor, or service provider to SIG is deemed a serious issue for which action may be taken, potentially resulting in the termination of any agreement.

SIG will assist individuals in the EU/EEA and Switzerland in protecting their privacy and will provide them opportunities to raise concerns about the Processing of their Personal Data.

Individuals in the EU/EEA and Switzerland have the right to make Personal Data access requests. If an individual makes such a request, SIG will provide the information requested which may contain some or all of the following information, along with other
information as required by applicable law:

  • Whether or not his/her Personal Data is Processed and if so why, the categories of Personal Data Processed and the source of the data if it is not collected from the individual consistent with applicable law, SIG’s obligations to its clients and intelligence industry best practices;
  • To whom his/her Personal Data is or may be disclosed consistent with applicable law, SIG’s obligations to its clients and with intelligence industry best practices, including to recipients located outside the EU/EEA or Switzerland and the safeguards that apply to such data transfers; and
  • For how long his/her Personal Data is stored (or how that period is decided).

Disclosures by SIG will normally be in electronic form if the requester has made a request electronically unless he/she agrees otherwise.

If the requestor wants additional copies, SIG charges a reasonable fee, which will be based on the administrative cost to SIG of providing the additional copies.

To make an access request, individuals in the EU/EEA or Switzerland should send their request to SIG’s Data Protection Officer by email at DPO@sigintelligence.com or call at +1-817-999-6667 or write to:

Strategic Insight Group
Data Protection Officer
6777 Camp Bowie Blvd
Suite 100
Fort Worth, Texas 76116

SIG may need to ask for proof of identification before a request can be processed. SIG will inform the requestor if it needs to verify his/her identity and the documents it requires.

SIG will normally respond to a request within a period of one month from the date a request is received. In some cases, such as where SIG Processes large amounts of the individual’s data, it may respond within three months of the date the request is received.

SIG will write to the requestor within one month of receiving the original request to tell him/her if more time is needed to complete the response to their request.

If an EU/EEA or Swiss individual submits a request which is manifestly unfounded or excessive, SIG is not required to comply with it. Alternatively, SIG can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request.

Individuals in the EU/EEA and Switzerland also have a number of other rights in relation to their Personal Data. They can request SIG to:

  • Correct inaccurate Personal Data to the extent consistent with applicable law, SIG’s obligations to its clients and intelligence industry best practices;
  • Stop Processing or erase Personal Data that is no longer necessary for SIG’s purposes of Processing to the extent consistent with applicable law, SIG’s obligations to its clients and intelligence industry best practices;
  • Stop Processing or erase Personal Data if the individual's interests override SIG’s legitimate grounds for processing the Personal Data including to the extent consistent with applicable law, SIG’s obligations to its clients and intelligence industry best practices;
  • Stop processing or erase Personal Data if the processing is unlawful; and/or
  • Stop processing Personal Data for a period if the requestor asserts the Personal Data is inaccurate or if there is a dispute about whether or not the requestor's interests override SIG's legitimate grounds for processing the Personal Data.

Where SIG determines that the requestor’s Personal Data is accurate to the extent consistent with applicable law and intelligence industry best practices, SIG will include in SIG’s Personal Data file the alternative text that the requestor believes to be appropriate alongside SIG’s original information. If it is determined that the Personal Data needs to be updated or corrected by SIG, SIG will use reasonable efforts to inform the relevant SIG client and Third Parties which were provided with the information previously.

To ask SIG to take any of these steps, individuals in the EU/EEA or Switzerland should contact SIG’s Data Protection by email at DPO@sigintelligence.com or write to us at:

Strategic Insight Group
Data Protection Officer
6777 Camp Bowie Blvd
Suite 100
Fort Worth, Texas 76116

or call us at +1-817-999-6667

Individuals in the EU/EEA and Switzerland may also make data privacy and/or data use complaint about SIG to the UK Information Commissioner’s Office (ICO) here https://ico.org.uk/concerns/ or by calling the UK ICO helpline at 0303-123-1113.
Individuals in Switzerland can also make a complaint to the Swiss Federal Data Protection and Information Commissioner here
https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/task.html. Individuals in the EU/EEA can also make a complaint to the Data Protection Authority in the EU/EEA Member State where they live or work listed here http://ec.europa.eu/justice/dataprotection/article-29/structure/data-protection-authorities/index_en.htm

OTHER EU/EEA and SWISS PROVISIONS

International Transfers of Personal Data

SIG’s website is provided from within the United States and is subject to the state and federal laws of the United States. If you are located outside of the United States, your Personal Data is being transferred to, stored, used and shared in the United States.

Personal Data is also transferred by SIG to countries outside the EU/EEA or Switzerland for SIG’s legitimate interests in processing Personal Data where necessary to perform its obligations to its clients and to exercise its rights and fulfill its duties under law. SIG transfers Personal Data outside the EU/EEA and Switzerland to the U.S. on the basis of Privacy Shield Frameworks.

EU-U.S. and Swiss-U.S. Privacy Shield Frameworks

SIG complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member
countries (including Iceland, Liechtenstein, and Norway) and Switzerland transferred to the United States pursuant to Privacy Shield. SIG has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, SIG is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal
information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under
Privacy Shield, should direct their query to DPO@sigintelligence.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to DPO@sigintelligence.com.

SIG’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, SIG remains responsible and liable under the Privacy
Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless SIG proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, SIG commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals
with Privacy Shield inquiries or complaints should first contact SIG

Strategic Insight Group
Data Protection Officer
6777 Camp Bowie Blvd
Suite 100
Fort Worth, Texas 76116

  • or call us at +1-817-999-6667

SIG has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to
you.

If your complaint involves human resources data transferred to the United States from the EU and/or Switzerland in the context of the employment relationship, and SIG does not address it satisfactorily, SIG commits to cooperate with the panel established by the EU data protection authorities (DPA Panel) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable and to comply with the advice given by the DPA panel and/or Commissioner, as applicable with regard to such human
resources data. To pursue an unresolved human resources complaint, you should contact the state or national data protection or labor authority in the appropriate jurisdiction. Complaints related to human resources data should not be addressed to
the BBB EU PRIVACY SHIELD.

Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at
https://www.privacyshield.gov/article?id=ANNEX-I-introduction