We operate and provide services in different regions around the globe. For all international transfers of personal data, we adhere to the principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability.
When there are international transfers of your personal information, we will ensure that an adequate level of protection is provided for the information by using one or more of the following approaches:
- We may enter into written agreements, such as standard contractual clauses, with recipients that require them to provide the same level of protection for the data.
- We may rely on other transfer mechanisms approved by authorities in the country from which the data are transferred.
Your personal information could be transferred, stored and processed in the United States using appropriate transfer mechanisms as required by applicable law. Please note, however, that the data protection laws in the United States may not be as comprehensive as those in your country of residence. Pursuant to the laws of the United States, we may be required to disclose personal information in response to requests by public authorities, including to meet national security or law enforcement requirements. To the best of our knowledge our systems are not subject to routine access by government authorities without warrants or appropriate accountability via established legal process.
2.1 EU-U. S. Privacy Shield and Swiss-U. S. Privacy Shield
Kobre & Kim participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (together, the Frameworks). Kobre & Kim is committed to subjecting all personal data received from the EU member countries and United Kingdom;
and Switzerland, respectively, in reliance on each Framework, to the Frameworks’ applicable principles.
To learn more about the Frameworks, and to view our certification, visit the Privacy Shield List maintained by the U.S. Department of Commerce at
Kobre & Kim takes responsibility for the processing of personal data received under each Privacy Shield Framework, including with respect to any transfers to a third party acting as an agent on its behalf. Kobre & Kim complies with the Frameworks’ principles for all onward transfers of personal data from the EU, the United Kingdom; https://www.privacyshield.gov/article?id=Privacy-Shield-and-the-UK-FAQs, and Switzerland, including the onward-transfer liability provisions.
With respect to personal data received or transferred pursuant to the Frameworks, Kobre & Kim is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC). In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data-use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
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2.2 Asia-Pacific Economic Cooperation (APEC) Cross-border Privacy Rules (CBPR) System
Kobre & Kim's privacy practices comply with the APEC Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal data transferred among participating APEC economies. More information about the APEC framework can be found here [PDF].
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