Privacy Shield Notice
Effective as of: January 9, 2019
This Notice applies to individuals located in the European Economic Area (“EEA”) and Switzerland with respect to the transfer of personal information to the United States. The Notice describes our standards and procedures for handling personal information transferred from the EEA and Switzerland to the United States. In this Notice where we use the words “personal information” we use these words to describe information that
COMPLIANCE WITH THE EU-U.S. AND SWISS-U.S. PRIVACY SHIELD FRAMEWORKS
We comply with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EEA or Switzerland, as the case may be, to the United States. Blueback Global has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Notice 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/.
Scope. Our commitment to the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework covers personal information collected from the EEA or Switzerland and transferred to the U.S., including Blueback Global users, Site visitors (including job applicants), service provider, and human resources data. Blueback employees please see the Internal Privacy Notice for more information on Privacy Shield as it relates to human resources data.
Choice. You also have the right to opt out of (i) disclosures of your personal information to third parties not identified at the time of collection or subsequently authorized and (ii) uses of personal information for purposes materially different from those disclosed at the time of collection or subsequently authorized. To exercise this right, please see the “Contact Us” section below.
Accountability for Onward Transfer. If we receive personal information subject to our certification under the Privacy Shield and then transfer such information to a third-party service provider acting as an agent on our behalf, we have certain liability under the Privacy Shield if the agent processes such information in a manner inconsistent with the Privacy Shield except when we are not responsible for the event giving rise to the damage.
Security. We have taken reasonable steps to help protect the personal information we collect. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee the security of your information in all circumstances. If you have any questions about the security of our Services, please contact us using the email address listed in “Contact Us” section below.
RECOURSE, ENFORCEMENT AND LIABILITY
Our Internal Recourse Mechanism. In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints should first contact us at [email protected] or at the address listed in the “Contact Us” section below. We will respond to your request within a reasonable timeframe, but in no event less than forty-five (45) days after receipt of your complaint.
Independent Recourse Mechanism. If a complaint cannot be resolved through our internal process, we commit to cooperate with the panel established by the EU/EEA data protection authorities (DPAs) or the Swiss Federal Data Protection and Information Commissioner (FDPIC) and will comply with the advice given by the DPAs with regard to personal information transferred from the EU/EEA and with the advice given by the FDPIC with regard to personal information transferred from Switzerland. Such individuals may direct complaints about their personal information to their respective DPA or the FDPIC (as applicable).
Binding Arbitration. You have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.
Regulatory Oversight. The Federal Trade Commission has jurisdiction over our compliance with the Privacy Shield.
CHANGES TO THIS NOTICE
We may update this Notice to account for changes consistent with the requirements of the EU-U.S. and/or Swiss-U.S. Privacy Shield Frameworks. Any changes we make to this Notice in the future will be posted on this page. The updated Notice will take effect as soon as it has been updated or otherwise communicated to you. We encourage you to review this Notice for updates each time you use our Services.
If you have questions about this Notice or our information handling practices, you can e-mail us at [email protected], or by mail at 21710 Stevens Creek Blvd., Suite 225, Cupertino, CA 95014.