Privacy Policy

Last Updated 06/13/2024

GDPR
We only collect the information we need to assist you in your transition with your permission. As every transition is different, the amount of information we request differs. If you would like to receive a report of all your personal information, you may send a request to [email protected]. When your transition services have been completed, you may request to have all your personal information removed from our systems by sending a request to [email protected]. If you would like us to transmit your data to another company, please send a request to [email protected]. If your personal information is ever compromised in our systems, you will be notified within 72 hours.

Data Privacy Framework
Herring IMPACT Group, LLC complies with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF as outlined by the U.S. Department of Commerce. Herring IMPACT Group LLC adheres to the EU-U.S. DPF Principles, the Swiss-U.S. DPF Principles, and in addition the Principles of the UK Extension to the EU-U.S. DPF as they apply to personal data. To learn more about the Data Privacy Framework program, please visit https://www.dataprivacyframework.gov/ .
In compliance with the Data Privacy Framework Principles, Herring IMPACT Group LLC commits to resolve complaints about our collection or use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our Data Privacy Framework policy should first contact Herring IMPACT Group LLC at:
Via email: [email protected]
Via telephone: 314-558-2700
Via mail:
Privacy Officer
12977 N Outer 40 Drive
Suite 300
St Louis, MO 63141

Herring IMPACT Group LLC has further committed to refer unresolved Data Privacy complaints to JAMS, 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 contact or visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

With respect to personal data received or transferred pursuant to the Data Privacy, Herring IMPACT Group LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Disclosure of Personal Information to Third Parties
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
Personal Identifiable Information (PII) is defined as: Any representation of information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means. Herring IMPACT Group LLC does not share personal information collected from you with third parties. Any onward transfer of your Personal Information is pursuant to the EU-U.S. Data Privacy Framework. Herring IMPACT Group LLC accepts liability for onward transfers.
Your Personal Information may be shared under the following circumstances:
(i) if Herring IMPACT Group LLC is required to do so by law enforcement authorities or government agencies; and (ii) in connection with investigations or other efforts to prevent illegal activities or pertaining to public safety.
Herring IMPACT Group LLC may disclose and transfer your personal information during a merger or during the divestiture of company assets. However, Herring IMPACT Group LLC will require the acquiring organization to agree to protect the privacy of your personal information consistent with this Privacy Notice.

Access to Personal Information
There may be times that you wish to access your personal information. Herring IMPACT Group LLC makes good faith efforts to provide you with access to your personal information so you can instruct us to correct or update the personal information if it is inaccurate or delete your personal information if Herring IMPACT Group LLC is not required to retain it by law or for a legitimate business purpose. To receive a copy of your personal information, or to provide instructions to us on what you want corrected or updated, send us an e-mail at: [email protected].

Opting Out: How You Control the Use of Your Personal Information
In the event you decide that you want to opt out from Herring IMPACT Group LLC's use of your personal information you can notify IMPACT Group by email at [email protected].

Changes to this Privacy Notice and Notification to You
Herring IMPACT Group LLC reserves the right, in its sole discretion, to make changes to this Privacy Notice. When changes are made to the Privacy Notice, the "Last Revision Date" field at the top of the Privacy Notice will be updated accordingly. Changes to the Privacy Notice become effective upon posting and updating the "Last Revision Date". Herring IMPACT Group LLC encourages you to periodically review the Privacy Notice to be informed of any changes.

Privacy Policy - Canada
Herring IMPACT Group LLC is committed to maintaining the privacy of personal information collected by us in connection with our services. This Privacy Policy covers the personal information handling practices of IMPACT GROUP and describes the principles IMPACT GROUP follows regarding personal information collected, used, and disclosed in connection with our provision of our services. All Herring IMPACT Group LLC personnel are obliged to adhere to the provisions of the Privacy Policy.

Personal information that Herring IMPACT Group LLC handles is subject to the federal Personal Information Protection and Electronic Documents Act ("PIPEDA"). This Policy adopts the definition of personal information as set out in PIPEDA and is summarized as: any information about a reasonably identifiable individual, except for business card information such as name, title, business address, and business telephone number.

Collection of Personal Information
Herring IMPACT Group LLC only collects personal information for the purpose of providing its services. Herring IMPACT Group LLC collects personal information in accordance with the law. Generally, Herring IMPACT Group LLC collects personal information directly from the individuals to which it relates. Such collection may be done at the start of our relationship with a client or during the course of our services.

Herring IMPACT Group LLC may collect information about individuals from other sources including, for example:

a government agency or registry;
other professionals who serve our clients;
information contained in publicly available sources;
other parties or witnesses in the context of investigation or litigation files; or
other parties or participants to a commercial transaction.

Personal information is collected to provide services. Herring IMPACT Group LLC does not collect personal information for the purpose of marketing to clients/customers.

Consent
Before Herring IMPACT Group LLC engages in collection, use and/or disclosure of personal information, it obtains consent from the individual to which the personal information pertains, except if the information is publicly available, and/or as may be permitted or required by law. In some cases, written express consent is obtained, and, in other cases, consent may be implied or obtained orally (such as when a customer calls and asks about the status of a certain request).

In keeping with the principles set out in PIPEDA, and as a general rule for readers of this Policy, Herring IMPACT Group LLC determines the level of consent (written versus oral, and express versus implied) needed based on the sensitivity of the personal information at issue - the more sensitive the personal information, the more likely that the consent will be obtained on an express written basis.

Consent may, at any time, be withdrawn or varied. Herring IMPACT Group LLC requires that a request for withdrawal or variation of consent be provided in writing to Herring IMPACT Group LLC 's Privacy Officer.

As an internationally recognized provider of specialized services, Herring IMPACT Group LLC works with its related companies and uses some of the advanced information storage measures made available through Herring IMPACT Group LLC and its affiliates and service providers. In doing so, personal information may be transferred outside of Canada to be processed, stored, or maintained, including in the United States. Personal information transferred outside of Canada is subject to the laws of the receiving jurisdiction, including laws relating to disclosure of personal information.

Use, Disclosure and Retention of Personal Information
Herring IMPACT Group LLC does not use or disclose personal information for purposes other than those for which it was collected, except:

with the express consent of individual;
as required by a lawful order, subpoena, warrant or other request for disclosure;
as may be required by law;
in order to comply with the requirements of any regulatory body that governs any of our professional practices;
to anyone we reasonably believe is an agent of a client;
where the disclosure is to a purchaser or prospective purchaser of all or a part of Herring IMPACT Group LLC 's business;
if we engage a third party to provide administrative services to us (such as computer back-up services, data processing, archival file storage, or insurance) and the third party is bound by privacy obligations that are consistent with this Policy; or
if we retain other professional firms on behalf of a client that require disclosure of personal information.

In addition, where Herring IMPACT Group LLC is acting in the capacity of an investigative body, Herring IMPACT Group LLC may collect, use and disclose personal information when the disclosure is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada, a province or a foreign jurisdiction.

Herring IMPACT Group LLC only retains personal information for as long as reasonably necessary to fulfill the purposes for which it was collected and to comply with its legal and regulatory obligations.

Accuracy
Personal information will be as accurate, complete and up to date as is reasonably possible and as is necessary for the purposes for which it is to be used. Although we acknowledge the importance of having accurate personal information, Herring IMPACT Group LLC does not vouch for, and is not responsible for, the accuracy of personal information that may be supplied by third party sources of information.

Access
Pursuant to PIPEDA, and subject to certain exceptions, individuals may seek to access their personal information that is in the custody or control of Herring IMPACT Group LLC. To obtain access, an individual must send an e-mail to [email protected] or call 1-314-558-2700. You may be required to go through a short identity verification process. If information is withheld, Herring IMPACT Group LLC will communicate its reasons for doing so.

Security
Herring IMPACT Group LLC uses physical, organizational, technological and other measures to keep personal information secure from unauthorized access. Herring IMPACT Group LLC maintains secure office premises and work environments conducive to private discussions and enforces confidentiality obligations that are communicated and agreed to by all Herring IMPACT Group LLC employees.

Accountability
Herring IMPACT Group LLC has appointed a Privacy Officer who is responsible for ensuring Herring IMPACT Group LLC 's compliance with the requirements of these privacy principles and applicable privacy laws. Should you have any questions regarding this Policy or concerns with respect to Herring IMPACT Group LLC 's compliance with these privacy principles and applicable privacy laws, please submit inquiries, in writing, to Herring IMPACT Group LLC 's Privacy Officer at 12977 North Outer 40 Drive, Suite 200, Suite 300, St Louis, MO, 63026, or via email to [email protected].

Changes to this Policy
We may amend this Policy at any time. We will post the Policy as amended on our website and will take reasonable steps to inform you of any amendments. We will obtain the necessary consent required under applicable privacy laws if we seek to collect, use or disclose your personal information for purposes other than those to which consent has been obtained unless otherwise required or permitted by law.