Privacy Shield Policy
This Privacy Shield Policy was last updated on October 24, 2017.
Great Feats LLC. (“Great Feats”) has adopted this Privacy Shield Policy (“Policy”) to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that Great Feats obtains from Customers located in the European Union and Switzerland.
The Federal Trade Commission (FTC) has jurisdiction over Great Feats’ compliance with the Privacy Shield.
All Great Feats employees who handle Personal Data from Europe and Switzerland are required to comply with the Principles stated in this Policy.
Capitalized terms are defined in the Defined Terms section of this Policy.
This Policy applies to the processing of Individual Customer Personal Data that Great Feats receives in the United States concerning Individual Customers who reside in the European Union and Switzerland. Great Feats provides products and services to businesses and consumers.
This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)
COLLECTION AND USE OF PERSONAL DATA
Great Feats provides various solutions to its Individual Customers who purchase its products. Great Feats collects Personal Data from Individual Customers when they purchase its products, register with our website, log-in to their account, complete surveys, request information or otherwise communicate with us.
The Personal Data that we collect may vary based on the Individual Customer’s interaction with our website and request for our services. As a general matter, Great Feats collects the following types of Personal Data from its Individual Customers: contact information, including, a contact person’s name, work email address, work mailing address, work telephone number, title, and company name, as well as payment information (which might include credit card and/or bank account information). Individual customers have the option to log into their accounts online and to request service online; we will collect information that they choose to provide to us through these portals.
When Individual Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website.
The information that we collect from Individual Customers is used for selling the products and services they buy from us, managing transactions, reporting, invoicing, renewals, other operations related to providing services and products to the Individual Customer.
Great Feats serves as a service provider to its Individual Customers. In our capacity as a service provider, we will receive, store, and/or process Personal Data from End Users. In such cases, we are acting as a data processor and will process the personal information from End Users on behalf of and under the direction of our partners and/or agents. The information that we collect from our Individual Customers in this capacity is used for managing transactions, reporting, invoicing, renewals, other operations related to providing services to the Individual Customer, and as otherwise requested by our partner and/or agent.
Great Feats uses Personal Data that it collects directly from its Individual Customers and from End Users on behalf of its partners indirectly in its role as a service provider for the following business purposes, without limitation:
- Maintaining and supporting its products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including managing transactions, reporting, invoices, renewals, and other operations related to providing services to an Individual Customer)
- Storing and processing data, including Personal Data, in computer databases and servers located in the United States;
- Verifying identity (e.g., for online access to accounts);
- As requested by the Individual Customer;
- For other business-related purposes permitted or required under applicable local law and regulation;
- As otherwise required by law.
Great Feats does not disclose personal information to third parties for purposes that are materially different than what it was originally collected for. Should this change in the future, we will provide individuals with the option to opt-out.
DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA
Great Feats discloses Personal Data only to Third Parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.
Great Feats may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, Great Feats may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by Great Feats and they must either:
- Comply with the Privacy Shield principles or another mechanism permitted by the applicable EU and Swiss data protection law(s) for transfers and processing of Personal Data;
- Or agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy;
Great Feats also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure. Please be aware that Great Feats may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Great Feats is liable for appropriate onward transfers of personal data to third parties.
Great Feats does not collect Sensitive Data from its Individual Customers.
DATA INTEGRITY AND SECURITY
Great Feats uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. Great Feats has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to Great Feats’ electronic information systems requires user authentication via password or similar means. Great Feats also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.
Further, Great Feats uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.
ACCESSING PERSONAL DATA
Great Feats personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
Individual Customers have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which Great Feats collected it. Individual Customers may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and Great Feats policies. Upon reasonable request and as required by the Privacy Shield principles, Great Feats allows Individual Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Individual Customers may edit their Personal Data by logging into their account profile or by contacting Great Feats by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a written or email request to Great Feats.
Great Feats will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise:
- Legally binding request for disclosure of the Personal Data by a law enforcement authority
- Request received from the Data Subject.
If Great Feats receives a request to access, change or delete his/her Personal Data from an End User whose data is stored on behalf of an Individual Customer, then Great Feats will refer that request to the Individual Customer and will support the Individual Customer as needed to comply with the request.
Great Feats will endeavor to respond in a timely manner to all reasonable written requests to access, change, or delete Personal Data.
CHANGES TO THIS POLICY
This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.
QUESTIONS OR COMPLAINTS
EU and Swiss Individual customers may contact Great Feats with questions or complaints concerning this Policy at the following address: email@example.com
ENFORCEMENT AND DISPUTE RESOLUTION
In compliance with the US-EU and Swiss-US Privacy Shield Principles, Great Feats commits to resolve complaints about your privacy and our collection or use of your personal information. EU and Swiss individuals with questions or concerns about the use of their Personal Data should contact us at: firstname.lastname@example.org.
If a Customer’s question or concern cannot be satisfied through this process Great Feats has further committed to refer unresolved privacy complaints under US-EU Privacy Shield and Swiss-US Privacy Shield to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus.
If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by Great Feats, EU and Swiss individuals may bring a complaint before the BBB EU and Swiss Privacy Shield program can be found at: www.bbb.org/EU-privacy-shield/for-eu-consumers/. Finally, as a last resort and in limited situations, EU and Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
Great Feats commits to cooperate with EU and Swiss data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
“Individual Customer” means an Individual customer or client of Great Feats from EU or Switzerland. The term also shall include any individual agent, representative, of an individual customer of Great Feats and all employees of Great Feats where Great Feats has obtained his or her Personal Data from such Individual Customer as part of its business relationship with Great Feats.
“End User” means a Data Subject who uses the services provided by Great Feats to engage with a Great Feats client and whose Personal Data is stored and maintained on behalf of that Individual Client by Great Feats.
“Data Subject” means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.
“Employee” means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of Great Feats or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.
“Europe” or “European” refers to a country in the European Union.
“Personal Data” as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual’s name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term “person” includes both a natural person and a legal entity, regardless of the form of the legal entity.
“Sensitive Data” means Personal Data that discloses a Data Subject’s medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.
“Third Party” means any individual or entity that is neither Great Feats nor a Great Feats employee, agent, contractor, or representative.