Privacy Policy

Privacy Shield Policy

Effective: January 8th, 2020

EU-US Privacy Shield Framework Luther Systems US Incorporated (“we,” “us,” “our”) complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom to the United States in reliance on Privacy Shield. Luther Systems US Incorporated 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, Luther Systems US Incorporated is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, you, as an EU and UK individual 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 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 privacy@luthersystems.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, 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 privacy@luthersystems.com.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Luther Systems US Incorporated’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. Individuals have been informed about the type or identity of third parties to which Luther Systems discloses personal information and the purposes for which it does so. In particular, Luther Systems US Incorporated remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Luther Systems US Incorporated proves that it is not responsible for the event giving rise to the damage.

If you would like to see the types of date we collect, how we use that data, third parties we disclose your data to, or your rights under GDPR please see our Privacy Notice.

In compliance with the Privacy Shield Principles, Luther Systems US Incorporated 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 UK individuals with Privacy Shield inquiries or complaints should first contact Luther Systems US Incorporated by email at privacy@luthersystems.com or via post at:

Samuel Wood
20 South Santa Cruz Avenue, Suite 300,
Los Gatos, CA, 95030

Luther Systems US Incorporated has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://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 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.

For a more detailed version of our Privacy Shield Policy, please visit https://www.luthersystems.com/luther-systems-privacy-policy.