Privacy Shield Policy
Effective on January 3, 2019
Introduction and Scope
EU-U.S. and Swiss-U.S. Privacy Shield Frameworks
With respect to personal data processed in the scope of this Policy, LGH complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (the “Privacy Shield”), as adopted and set forth by the U.S. Department of Commerce, regarding the processing of personal data transferred from the European Union, the European Economic Area, the United Kingdom, and Switzerland to the United States or that it otherwise receives in reliance on Privacy Shield. LGH commits to adhere to and has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to all personal data that LGH receives in reliance on the Privacy Shield.
VeraSafe Privacy Program
LGH is a member of the VeraSafe Privacy Program, meaning that with respect to personal data processed in the scope of this Policy, VeraSafe has assessed LGH’s data governance and data security for compliance with the VeraSafe Privacy Program Certification Criteria. The certification criteria require that participants maintain a high standard for data privacy and implement specific best practices pertaining to Policy, onward transfer, choice, access, data security, data quality, recourse, and enforcement.
Where a privacy complaint or dispute cannot be resolved through LGH’s internal processes, LGH has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Privacy Shield Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/
If a complaint or dispute related to personal data of employees of LGH Group Companies cannot be resolved through LGH’s internal process, LGH has agreed to cooperate with the EU data protection authorities and the Swiss Federal Data Protection and Information Commissioner and to participate in the dispute resolution procedures of the panel established by such data protection authorities.
Categories of Personal Data
We may process the following types of personal data:
- biographical information, such as first and last name;
- professional information, such as job title and trade;
- contact information, such as e-mail, work and cell phone numbers, fax number;
- financial/payment information; and
- any other information entered into the notes field.
We may process the following additional categories of personal data related to employees of LGH Group Companies:
- date of birth;
- date of hire;
- national ID number (last 4 digits);
- home address;
- and contact information, such as e-mail, work and cell phone numbers, fax number.
In the context of this Policy, LGH acts as an agent, also known as a data processor, for the personal data we process through LiftWare. This means that the data controllers, the LGH Group Companies, determine the type of personal data they provide to LGH to process on their behalf. The data controllers are responsible for providing this Policy to the individuals whose personal data will be collected and provided to LGH.
How We Receive Personal Data
We receive your personal data from LGH Group Companies.
Basis of Processing
Within the scope of this Policy, we process personal data based on the documented instructions of LGH Group Companies.
Purpose of Processing
We process personal data for the purposes of providing support to LGH Group Companies with respect to:
- customer relationship management (CRM);
- enterprise resource planning (ERP); and
- managing rental and sale of equipment.
We retain personal data for as long as instructed by the applicable data controller. We will delete such personal data within six months of receiving an instruction to do such by the data controller.
Sharing Personal Data with Third Parties
We share personal data with our service providers, who process personal data on behalf of LGH. Such third parties include those:
- providing IT systems and infrastructure; and
- telecommunication services.
Our service providers may be located outside of the United States; however, we will either obtain your explicit consent to transfer your personal data to such third parties, or we will require that those third parties maintain at least the same level of confidentiality that we maintain for such personal data. LGH remains liable for the protection of your personal data within the scope of our Privacy Shield certification that we transfer to our service providers, except to the extent that we are not responsible for the event giving rise to any unauthorized or improper processing.
Other Disclosure of Your Personal Data
We may disclose your personal data (i) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders, or (ii) if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change, or (iii) to our subsidiaries or affiliates only if necessary for business and operational purposes as described in the section above.
We reserve the right to use, transfer, sell, and share aggregated, anonymous data, about individuals whose personal data we process in our LiftWare application, as a group, for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, and customers. Such data will not include any personal data.
If we must disclose your personal data in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your personal data will maintain the privacy or security of your personal data.
Data Integrity & Security
LGH has implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect personal data from unauthorized processing such as unauthorized access, disclosure, alteration, or destruction.
Access & Review
If we store personal data about you, you may have a right to request access to, and the opportunity to update, correct, or delete, such personal data. You may also have the right to opt out of having your personal data shared with third parties and to revoke your consent that you have previously provided for your personal data to be shared with third parties, except as required by law. You also have the right to opt out if your personal data is used for any purpose that is materially different from, but nevertheless compatible with the purpose(s) for which it was originally collected or subsequently authorized by you. Requests should be sent to the LGH Group Company who provided your personal data to LGH, or to LGH directly at as described in the “Contact Us” section below. LGH has limited rights to access personal data LGH Group Companies provide to us. Therefore, if you contact us with such a request, please provide the name of LGH Group Company who provided your personal data to us. We will forward your request to that organization and assist them, as needed, as they respond to your request.
Privacy of Children
We do not knowingly collect personal data from anyone under 18. In the event that we learn that we process personal data from a child under age 13, we will delete the information we have stored as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us using “Contact Us” section below.
If we make any material change to this Policy, we will post the revised Policy to this web page and update the “Effective on” date above to reflect the date on which the new Policy became effective.
If you have any questions about this Policy or our processing of your personal data, please write to our IT Manager by email at PrivacyShield@RentLGH.com or by postal mail at:
Lifting Gear Hire Corporation
Attn: IT Manager
9925 S. Industrial Drive
Bridgeview, IL 60455
Please allow up to four weeks for us to reply.
If your dispute or complaint can’t be resolved by us, nor through the dispute resolution program established by VeraSafe, you may have the right to require that we enter into binding arbitration with you pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.
LGH is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.