Privacy Shield Policy
1. Purpose and intent
This Privacy Shield Policy (“Policy”) sets out how Leoforce LLC., together with its subsidiaries and affiliates in the United States of America (“U.S.”) (collectively, “Leoforce,” “we” or “us”) collect, use, process and protect the personal data of individual(s) (“you” or “your”) that are based in the European Economic Area (“E.U.”), Switzerland (“Swiss”) and United Kingdom (“U.K.”).
It is important that you understand this Policy, together with any other privacy policies we may provide on specific occasions when we are collecting or processing personal data about you so that you are aware of how and why we are using such information.
2. Data protection principles
Leoforce complies with the E.U.-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the E.U., Swiss and U.K. to the U.S. Leoforce has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. For purposes of enforcing compliance with the Privacy Shield, Leoforce is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/, and to view our certification please visit https://www.privacyshield.gov/participant?id=a2zt0000000PKQVAA4&status=Active.
3. Personal data collection
The personal data which we collect is specified in https://leoforce.com/data-privacy-policy/.
4. How we use the personal data
- To identify you as a potential candidate for a job position with one or more of our clients (which from an E.U. data protection perspective may amount to profiling).
- To combine your personal data with personal data from a number of sources so that we may build a better picture of you and ensure the right candidates are matched with the right clients.
- To share your personal data with one or more of our clients where we believe your personal data matches the search criteria of such client.
- To share your personal data with third parties providing us with services, and to seek your approval to be contacted by one or more of our clients.
- To engage with you regarding your job application.
- To test, research, analyze, and improve our product development, including the development and improvement of our websites, products, and services.
Leoforce will only process personal data in ways that are compatible with the purpose that Leoforce collected it for, or for purposes that you later authorize. Before we use your personal data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt-out.
When we collect sensitive personal data, we will obtain your opt-in consent where the Privacy Shield requires, including if we disclose your sensitive personal data to third parties, or before we use your sensitive personal data for a different purpose than we collected it for or than you later authorized.
5. Data transfers to third-party agents or service providers
We may transfer personal data to our third-party agents or service providers who perform functions on our behalf. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the personal data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process personal data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing.
6. Disclosure made for national security or law enforcement
Under certain circumstances, we may be required to disclose your personal data in response to valid requests by public authorities, including to meet national security or law enforcement requirements and we ensure to be compliant with the Privacy Shield Principles.
7. Access rights
You may have the right to access the personal data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your personal data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances, we may charge a reasonable fee for access to your information.
8. Data security
Leoforce maintains reasonable and appropriate security measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield Principles. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
9. Data retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We will retain and securely destroy your personal data in accordance with our retention policies.
10. International transfers of personal data
We shall not transfer your personal data from countries participating in the E.U., Swiss and U.K. to those which do not, or from the EU, Swiss and U.K. to international organizations unless the recipient country or the particular person or entity receiving the data ensures an adequate level of protection for the personal data received. For instance, if we are to transfer your personal data from the E.U. to a recipient in the U.S., we shall make sure that the recipient participates in the E.U.-U.S. Privacy Shield Framework, having thus self-certified itself as ensuring a level of protection of personal data.
11. Questions or complaints
You can direct any questions or complaints about the use or disclosure of your personal data to us at email@example.com, or via postal mail at Leoforce, LLC, 500 W Peace St, Raleigh, NC 27603, or via phone at +1 919-800-0110. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your personal data within 45 days of receiving your complaint.
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (a) raised your compliant directly with Leoforce and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the U.S. Department of Commerce an opportunity to resolve the complaint. Leoforce has committed to refer unresolved Privacy Shield complaints to JAMS Privacy Shield Program, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit JAMS Mediation, Arbitration, ADR Services (jamsadr.com) for more information or to file a complaint.
12. Changes to this policy
Leoforce reserves the right to modify or amend this Policy at any time and for any reason. Any changes to this Policy posted on the website apply as soon as they are posted. By continuing to use the website after any changes are posted, you acknowledge acceptance of those changes.
Updated: 1st September, 2022