Last Revision Date:May 13, 2018

(A) This Policy          

This Policy is issued by the entities listed in Section (M)below (together, “KLDiscovery”, “we”, “us” or “our”). This Policy is addressed to individuals outside our organisation with whom we interact, including visitors to our websites (our “Websites”), customers, and other users of our Services (together, “you”). Defined terms used in this Policy are explained in Section (N) below.  

For the purposes of this Policy, KLDiscovery is the Controller of your Personal Information.   Contact details are provided in Section (M) below for the applicable KLDiscovery entity that can answer queries about the use and processing of your Personal Information.      

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy. We may notify you in case of material changes and seek your consent to those changes, where required by applicable law.            

KLDiscovery operates under the following brands:  KLDiscovery, Ontrack and Ibas.       
KLDiscovery通过以下品牌开展业务:KLDiscovery, Ontrack 以及 Ibas。

(B) Processing your Personal Information 

Collection of Personal Information: We may collect Personal Information about you:     

  • When you contact us via email, telephone or by any other means.  
  • In the ordinary course of our relationship with you (e.g., Personal Information we obtain in the course of administering your payments).         
  • When we provide Services. 
  • When we receive your Personal Information from third parties who provide it to us, such as credit reference agencies or law enforcement agencies.  
  • When you visit any of our Websites or use any features or resources available on or through our Websites. When you visit a Website, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Website and other technical communications information), some of which may constitute Personal Information.  
  • When you submit your resume/CV to us for a job application.         

Creation of Personal Information: In providing our Services, we may also create Personal Information about you, such as records of your interactions with us and details of your order history.         

Relevant Personal Information: The categories of Personal Information (including Sensitive Personal Information, where applicable) about you that we may Process (with your consent, where required by applicable law) include:          

  • Personal details: name(s); gender; date of birth / age; nationality; and photograph.
  • Contact details: shipping address (e.g., for returning original media and/or storage devices); postal address; telephone number; email address; and social media profile details.          
  • Payment details: billing address; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; and card expiry date.
  • Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.        

Purposes for which we may Process your Personal Information: The purposes for which we may Process Personal Information (including Sensitive Personal Information, where applicable), subject to applicable law and with your consent (where required by applicable law), include:          

  • Our Websites: operating and managing our Websites; providing content to you; displaying advertising and other information to you when you visit our Websites; and communicating and interacting with you via our Websites.     
  • Provision of Services: administering your account with us; providing our Websites and other Services; providing Services in response to orders;  and communications in relation to those Services.        
  • Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) subject to ensuring that such communications are provided to you in compliance with applicable law.       
  • Direct marketing: sending you advertising and marketing communications (including via email, telephone, direct mail or other communication forms) relating to our products and services that may be of interest to you. See further information in Section (L) below.          
  • Communications and IT operations: management of our communications systems; operation of IT security; and IT security audits.       
  • Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations.  
  • Financial management: sales; finance; verifying and carrying out financial transactions in relation to payments you make, corporate audit; and vendor management.     
  • Surveys: engaging with you for the purposes of obtaining your views on our Services.     
  • Improving our Services: identifying issues with existing Services; carrying out data analytics, market research and data enrichment, planning improvements to existing Services; and creating new Services.        
  • Human Resources: administration of applications for positions with KLDiscovery.  

We will, where required by applicable laws and regulations, obtain consent from you if we wish to use your Personal Information for purposes other than those stated in this Policy.         

Voluntary provision of Personal Information and consequences of non-provision: The provision of your Personal Information to us is usually voluntary but may be a requirement necessary in order to enter into a contract with us and to enable us to fulfil our contractual obligations towards you. You are under no statutory obligation to provide your Personal Information to us; however, if you decide not to provide us with your Personal Information, we may not be able to conclude a contractual relationship with you and to fulfil our contractual obligations towards you.    

(C) Disclosure of Personal Information to third parties   

We may disclose your Personal Information (including Sensitive Personal Information, where applicable) to other entities within the KLDiscovery group as noted in Section (M) below, in order to fulfil our contractual obligations towards you or for legitimate business purposes (including providing Services to you and operating our Websites), in accordance with applicable law. In addition, we may disclose your Personal Information to:      

  • legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;        
  • accountants, auditors, lawyers and other outside professional advisors to KLDiscovery, subject to binding contractual or legal obligations of confidentiality;     
  • third party Processors (such as payment services providers; shipping/courier companies; technology suppliers, customer satisfaction survey providers, operators of “live-chat” services and processors who provide compliance services such as checking government issued prohibited lists, like the US Office for Foreign Asset Control), located anywhere in the world, subject to the requirements noted below in this Section (C); 
  • any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights, or any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;          
  • any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation), but only in accordance with the applicable law; and      
  • our Websites may use third party content. If you choose to interact with any such content, your Personal Information may be shared with the third party provider of the relevant social media platform. We recommend that you review that third party’s privacy policy before interacting with its content.      

If we engage a third-party Processor to Process your Personal Information, we will conclude a data processing agreement as required by the applicable laws with such third-party Processor so that the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Information in accordance with our prior written instructions; and (ii) use appropriate measures to protect the confidentiality and security of the Personal Information, which is of a comparable standard as applied by KLDiscovery; together with any additional requirements under applicable law.           

We may anonymize Personal Information about the use of the Websites (e.g., by recording such data in an aggregated format) and share such anonymized data with our business partners (including third party business partners).  

(D) International transfer of Personal Information

Because of the international nature of our business, we may need to transfer (with your consent) your Personal Information within the KLDiscovery Group, and to third parties as noted in Section (C) above, in connection with the purposes set out in this Policy. For this reason, unless otherwise prohibited by applicable laws and regulations, we may transfer your Personal Information to other countries that may have lower standards for data protection than the country in which you are resident due to different laws and data protection compliance requirements to those that apply in the country in which you are located.

Where we transfer your Personal Information from the EU to other countries, we do so, where required (and except for transfers from the EEA or Switzerland to the U.S.) on the basis of Standard Contractual Clauses. You may request a copy of our Standard Contractual Clauses using the contact details provided in Section (M) below.       

Where we transfer Personal Information from the EEA or from Switzerland to the USA, we do so under the EU–U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce, respectively. We have certified to the U.S. Department of Commerce that we adhere to the Privacy Shield principles. If, in respect of the transfer of Personal Information from the EU or Switzerland to the U.S. under our Privacy Shield certification, there is any conflict between the terms in this Policy and the Privacy Shield principles, the Privacy Shield principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with regard to the Privacy Shield principles. In compliance with the EU–U.S. and Swiss–U.S. Privacy Shield principles, we commit to resolve complaints about your privacy and our Processing of your Personal Information. For inquiries or complaints regarding this Policy please first contact us using the contact information in Section (M) below. We have further committed to refer unresolved privacy complaints under the EU–U.S. and Swiss–U.S. Privacy Shield principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the USA and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield panel.
就隐私盾原则而言,我们受联邦商务委员会的调查及执法权力规制。在遵循欧盟-美国隐私盾框架以及瑞士-美国隐私盾框架的前提下,我们承诺解决关于您的隐私以及我们对您个人信息处理的投诉。如有针对本政策的问题和投诉,请先通过下文(M)款所列联系方式联系我们。我们进一步承诺将欧盟-美国以及瑞士-美国隐私盾原则项下的未解决隐私投诉转交BBB EU PRIVACY SHIELD (位于美国的由商业促进局委员会运营的非营利组织,其提供非诉讼机制解决方案)。如果您未及时收到对您投诉的承认,或您的投诉未被满意地解决,请访问www.bbb.org/EU-privacy-shield/for-eu-consumers/以了解更多信息或呈交投诉。请注意,若您的投诉通过上述渠道未被解决,在有限的情况下,隐私盾合议庭可提供有约束力的仲裁选择。

Where we transfer your Personal Information from the People's Republic of China (excluding for the avoidance of doubt, Hong Kong SAR, Macau SAR and Taiwan) to other countries, on the basis that it is permitted by applicable laws and regulations and that we are satisfied that adequate levels of protection are in place to protect the integrity and security of your Personal Information or adequate security measures are adopted and compliance with applicable privacy and data protection laws and regulations.       

(E) Data Security       

We have implemented appropriate technical and organizational security measures designed to protect your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.           

You are responsible for ensuring that any Personal Information that you send to us are sent securely.   

(F) Data Accuracy     

We take every reasonable step to ensure that:     

  • your Personal Information that we Process are accurate and, where necessary, kept up to date; and        
  • any of your Personal Information that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.    

From time to time we may ask you to confirm the accuracy of your Personal Information.

(G) Data Minimisation          

We take every reasonable step to ensure that your Personal Information that we Process are limited to the Personal Information reasonably required in connection with the purposes set out in this Policy (including the provision of Services to you).       

(H) Data Retention    

We take every reasonable step to ensure that your Personal Information is only processed for the minimum period necessary for the purposes set out in this Privacy Policy. We will retain copies of your Personal Information in a form that permits identification only for as long as:

  • we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed); or          
  • your Personal Information are necessary in connection with the lawful purposes set out in this Privacy Policy, for which we have a valid legal basis (e.g., where your Personal Information are included in an order placed by your employer, and we have a legitimate interest in processing those data for the purposes of operating our business and fulfilling our obligations under that contract).    

Additionally, we will retain Personal Information for the duration of:         

  • any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Information, or to which your Personal Information may be relevant); and 
  • an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Information that are relevant to that claim).


In the event any relevant legal claims are brought, we may continue to Process your Personal Information for such additional periods as are necessary in connection with that claim.    

During the periods noted above in relation to legal claims, we will restrict our Processing of your Personal Information to storage of, and maintaining the security of, the Personal Information, except to the extent that the Personal Information needs to be reviewed in connection with any legal claim, or any obligation under applicable law.       

Once the periods above, each to the extent applicable, have concluded, we will permanently delete or destroy the relevant Personal Information. 

(I) Your legal rights 

Subject to applicable law, you may have a number of rights regarding the Processing of your Personal Information, including:      

  • the right to request access to, or copies of, your Personal Information that we Process or control, together with information regarding the nature, processing and disclosure of those Personal Information;        
  • the right to request rectification of any inaccuracies in your Personal Information that we Process or control;        
  • the right to request:
    • erasure of your Personal Information that we Process or control; or         
    • restriction of Processing of your Personal Information that we Process or control;
  • the right to withdraw your consent to Processing; and        
  • the right to lodge complaints with us or with a Data Protection Authority regarding the Processing of your Personal Information by us or on our behalf.          

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Information, please use the contact details provided in Section (M) below.

If we are providing you with Services based on orders, such provision of Services is regulated by contractual terms provided to you. In case of discrepancies between such terms and this Policy, this Policy is supplementary.     

(J) Cookies

A cookie is a small file that is placed on your device when you visit a website (including our Websites). It records information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Information through cookie technology, in accordance with our [Cookie Policy].     
Cookie是您访问网站(包括我们的网站)时加载于您的设备上的一个小文件。其记录您的设备、您的浏览器以及您的偏好和浏览习惯(在某些情况下)信息。我们可能根据我们的[Cookie Policy] 通过过Cookie技术处理您的个人信息。

(K) Terms of Use       

All use of our Websites is subject to our [Terms of Use]. 

(L) Direct Marketing 

Subject to applicable law, where you have provided explicit consent in accordance with the applicable law, we may Process your Personal Information to contact you via email, telephone, direct mail or other communication formats to provide you with information or Services that may be of interest to you,  using the contact details that you have provided to us and always in compliance with applicable law.          

You may unsubscribe from our promotional email list or newsletters at any time by simply clicking on the unsubscribe link included in every email or newsletter we send or by contacting us using the contact details provided in Section (M) below. After you unsubscribe, we will not send you further emails, but we may where permitted by applicable laws and regulations, continue to contact you to the extent necessary for the purposes of any Services you have requested.        

(M) Contact details   

If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Information by KLDiscovery, please contact the appropriate contact named below:       

The Controllers in respect of whom this policy is issued are as follows:         


Corporate Name

Registered Address and Contact


Kroll Ontrack Limited

UK Data Privacy Queries, Global House, 1 Ashley Avenue, Epsom, Surrey, KT18 5AD

Kroll Ontrack Legal Technologies Limited

UK Data Privacy Queries, Nexus, 25 Farringdon Street, London, EC4A 4AB


KrolLDiscovery Limited

Irish Data Privacy Queries, Unit 719, Kilshane Drive, Northwest Business Park, Ballycoolin, Dublin 15


IBAS Danmark ApS

Danish Data Privacy Queries, Gammel Kongevej 1, 1610 København V


IBAS Kroll Ontrack Oy

Finnish Data Privacy Queries, Lakkisepante 11
00620, Helsingfors


Kroll Ontrack B.V

Dutch Data Privacy Queries, Gustav Mahlerlaan 310 D, FOZ building 4th.floor Unit 4, 1082ME Amsterdam


IBAS Laboratories AB

Swedish Data Privacy Queries, Box 1005, 751 40 Uppsala



Norwegian Data Privacy Queries, Fjellgata 2, 2212 Kongsvinger


Kroll Ontrack GmbH

German Data Privacy Queries,
Geschäftsanschrift: Hanns-Klemm-Str. 5, 71034 Böblingen


Kroll Ontrack Srl

Italian Data Privacy Queries, GALLARATE (VA) VIA
MARSALA 34/A CAP 21013


Kroll Ontrack Sp. z o.o

Polish Data Privacy Queries, Katowice (40-082), ul. Jana III Sobieskiego 11, Poland


Kroll Ontrack Singapore Pte Ltd

Singapore Data Privacy Queries, 3 International Business Park
#02-27, Nordic European Centre
Singapore 609927


Kroll Ontrack Information Technology Service (Shanghai) Co., Ltd

Chinese Data Privacy Queries, Room 1004, Floor 10
Jing'An Kerry Centre Building 1 (North Building)
No. 1515, West Nanjing Road
Jing'an District
Shanghai, China
中国上海静安区南京西路1515号静安嘉里中心(北楼)10层1004室Chinese Data Privacy Queries


Kroll Ontrack (HK) Limited - Japan Branch

Japanese Data Privacy Queries, 24F, 1-7 Uchisaiwaichido 1 chome, Chiyoda-ku, Tokyo 100-0011, Japan

Hong Kong

Kroll Ontrack (HK) Limited

Hong Kong Data Privacy Queries, Room 1702, 17/F Central Plaza
18 Harbour Road
Wanchai, Hong Kong


Kroll Ontrack Iberia SL

Spanish Data Privacy Queries, C/Anabel Segura 7, 1ª planta, oficina B, 28108 – Alcobendas, Madrid


Kroll Ontrack Sarl

French Data Privacy Queries, 2, impasse de la Noisette, 91371 Verriéres-le-Buisson Cedex 413


Kroll Ontrack (Switzerland) GmbH

Swiss Data Privacy Queries, Hertistrasse 25, 8304 Wallisellen


Kroll Ontrack Pty Ltd

Australian Data Privacy Queries, 9/28 Donkin St, West End QLD 4101, Australia


LDiscovery, LLC

American Data Privacy Queries, Attn: Jason Davison, 8201 Greensboro Drive, Suite 300, McLean, VA 22102-3810

LDiscovery TX, LLC

American Data Privacy Queries, Attn: Jason Davison, 8201 Greensboro Drive, Suite 300, McLean, VA 22102-3810

Kroll Ontrack, LLC

American Data Privacy Queries, Attn: Jason Davison, 9023 Columbine Road
Eden Prairie, MN 55347


Kroll Ontrack Canada Co

Canadian Data Privacy Queries, 1871 Hollis Street, Suite 200, Halifax, NS, B3J 0C3

Please note that, where a Controller is listed outside the European Union, you may contact the entity in your jurisdiction.  We will endeavour to respond to your request with all applicable timeframes.

  • Definitions          
  • ‘Controller’ means the entity that decides how and why Personal Information is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.        
  • ‘Data Protection Authority’ means administration authorities at local and national levels in China that are relevant for protecting, supervising and administering cyber security within the scope of their respective responsibilities in accordance with applicable data protection law.         
  • EEA’ means the European Economic Area.
  • ‘Personal Information’ means any information recorded in electronic media or otherwise that could, solely or in combination with other information, be used to identify or reflect the activities of a specific individual. Examples of Personal Information that we may Process are provided in Section (B) above.        
  • ‘Process’, ‘Processing’ or ‘Processed’ means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.  
  • ‘Processor’ means any person or entity that Processes Personal Information on behalf of the Controller (other than employees of the Controller).   
  • Services’ means any services provided by KLDiscovery.   
  • ‘Sensitive Personal Information’ means any Personal Information divulgence, unauthorised disclosure or abuse of which may jeopardize the personal and property security or is likely to damage the reputation and physical mental health or lead to discriminatory treatment of the individual concerned. Examples include (this is not an exhaustive list): telephone numbers, information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, credit card record, transactions, medical records, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.