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EU/UK/Swiss-US Data Privacy Framework Statement

Lake Shore respects your privacy.

Lake Shore Cryotronics, Inc. (Lake Shore) complies with the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Lake Shore has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Lake Shore has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Notice

Lake Shore may collect your information when:

  • You visit our facility or interact with us on our website, via email or other electronic medium, in person, on the phone or at trade shows;
  • You place an order for products or services, or
  • You opt in to sharing usage analytics from your Lake Shore products

What we Collect

Depending upon the circumstance, the following information may be collected:

  • Basic contact information such as name, address, email address, and telephone number;
  • Username, password, IP address or domain,
  • Employment-related information such as employer, division, department, and title;
  • Identifying information, including names, addresses, nationality and birth date, of owners and others who exercise control over the management or direction of a corporate entity;
  • Meeting, call or visit notes,
  • Sales history that may include End User contact, Shipping contact, Purchasing contact and other Personal data,
  • Due Diligence Information documenting findings
    • Appearance on government-issued lists of sanctioned entities and persons, including, for example, restricted parties, denied persons, Specially Designated Nationals, debarred parties, excluded parties, blocked persons, embargoed countries and persons and other entities of concern;
    • Relationships with government or military officials, government ownership, and company employees who are current or former government officials;
    • Credit worthiness,
  • Other voluntarily-provided documents such as relevant certifications, due diligence reports, or other compliance documents;
  • Information on gifts that you may have offered to our employees such as date, description, business purpose, and approximate cost;
  • Under limited circumstances, documents and information to verify identity such as a passport, national identity card, driver’s license, or tax number; and
  • Aggregate usage analytics on targeted products.

While Lake Shore collects personal data; we do not collect sensitive personal data, as defined under the GDPR.

Why we collect it

We collect and use personal data for legitimate business purposes. We use it to provide products and services to our customers, to collaborate with our partners and to fulfill United States export and other regulatory requirements. Lake Shore will not use your personal information for any purpose other than the original intent or authorization. If opportunity were ever to arise, we will contact you to opt-in at that time.

What we will do with it

Lake Shore will securely retain personal data in order to contact customers and collaborators on past or current transactions and to fulfill notification and literature requests, such as newsletters. We will never sell or offer to sell your personal information for any purpose. Your personal information will not be disclosed by us to a third party for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized.

Under limited circumstances, Lake Shore will disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

How we secure your data

Data security is our priority and we are committed to safeguarding your information. We do this by:

  • Establishing policies and procedures for securely managing information;
  • Limiting employee access to sensitive information;
  • Protecting against unauthorized access to customer data by using physical security, firewalls;
  • Providing data privacy training to our employees;
  • Continually assessing our data privacy, information management and data security practices.

How we use website cookies

We use “cookies” (small text files that may be placed on your web browser when you visit our website). The information derived from cookies is used to enhance your experience on our website. You can decline cookies; however, if you do, our website might not function, as intended.

In addition, cookies may be used to track information and identify categories of visitors by items such as IP address, domain, browser type and pages visited to improve our service. We may use the Google Analytics™ web analytics tool to assist us in analyzing how visitors engage with our website and arrive at the public portion of the website.

Any data collected from cookies is used for administrative purposes; to assess the usage and performance of our services; to improve user experience; and as otherwise permitted by applicable law or regulation.

Disclosure of Information to Third Parties

We will not share your personal information with third parties, except as described herein or as authorized by you for legitimate business services.

We may share your information with a limited number of non-affiliated companies that perform routine support services for Lake Shore, including: those that provide professional, banking, legal, or accounting advice to Lake Shore; third parties who conduct or facilitate sanctions list screening; firms that provide hosting, database management services; credit processing and firms that are engaged to conduct routine audits of the personal information you have provided.

These third parties are required to maintain the confidentiality of your personal information, and to use your personal information only while providing specific services to Lake Shore, and only for the purposes that Lake Shore specifies. Lake Shore requires these third parties to maintain strict privacy policies, security and control. Under limited circumstances, your personal information may be disclosed to third parties to comply with applicable laws and regulations, such as in response to a subpoena or similar legal process, or to lawful requests by public authorities, including to meet national security or law enforcement requirements. Any other disclosure of your personal information will be pursuant to your express consent. Lake Shore recognizes its liability in cases of the onward transfers of personal data to third parties.

If you wish to opt out of having your personal information disclosed to a third party as described above, please contact the Lake Shore, at privacy@lakeshore.com. Understand that limiting these disclosures may make it difficult to complete transactions with Lake Shore or may limit future notifications having to do with past purchases.

Third party privacy statements from those with whom you or we may interact routinely as part of your web and purchasing experience are available. Links to these statements are available by emailing privacy@lakeshore.com.

How You May Access and Correct Information

You may request a listing of your personal information at any time by contacting us directly at privacy@lakeshore.com, and we will respond to your request within 30 days. You can alter, amend or delete this information, as required.

The EU/UK/Swiss-US Data Privacy Framework

With respect to personal data received or transferred pursuant to the Data Privacy Frameworks, Lake Shore Cryotronics is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission, which provides a framework for the transfer of information from the European Union, United Kingdom, and Switzerland to the United States. The Data Privacy Framework includes seven central Principles:

  1. Notice;
  2. Choice;
  3. Accountability for Onward Transfer;
  4. Security;
  5. Data Integrity and Purpose Limitation;
  6. Access; and
  7. Recourse, Enforcement and Liability.

The official Data Privacy List can be accessed at https://www.dataprivacyframework.gov/.

Changes to Our Privacy Policy

This policy provides a general statement of the ways in which Lake Shore protects your personal information. We may update this Privacy Policy at any time, with or without notice. In the event there are significant changes in the way we treat your personally identifiable information, we will update this policy and may send you an email summarizing the revisions. Of course, if you object to any of the changes to our terms contact us and we will find a resolution.

Our website at www.lakeshore.com will always state our most up to date policy.

If you have concerns, questions or would like further clarification about this policy, please contact us at privacy@lakeshore.com.

Complaint Resolution

In compliance with the EU-US Data Privacy Framework Principles, Lake Shore commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles.  European Union, Swiss and United Kingdom individuals with DPF inquiries or complaints should first contact Lake Shore at privacy@lakeshore.com.

Lake Shore has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers  for more information and to file a complaint. This service is provided free of charge to you.

If your DPF 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 https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2.