E.U. – U.S. and Swiss – U.S. Privacy Shield Policy
Effective day August 14, 2018
We, Seller Labs, LLC (“Seller Labs” “we” or “us”), are committed to protecting your privacy. This Policy sets out the privacy principles we follow with respect to transfers of personal data from the European Economic Area (“EEA”) and Switzerland to the United States, including personal data we receive from individuals residing in the EEA or Switzerland who visit our web and mobile sites or apps and/or who use any of our services or otherwise interact with us (“you”).
Seller Labs, LLC complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Seller Labs is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC).
Section 1 – Types of personal data we collect and use
Section 2 – Data transfers to third parties
Agents, consultants and service providers: We may share your personal data with our contractors and service providers who process personal data on our behalf to perform certain business-related functions. These companies include database service providers, backup and disaster recovery service providers, email service providers and others. When we engage another company to perform such functions, we may provide them with information, including personal data, in connection with their performance of such functions.
Our Group Companies: We may also share your personal data with our parent companies, subsidiaries and/or affiliates for purposes consistent with this Policy.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets.
Disclosures for National Security or Law Enforcement: Under certain circumstances, we may be required to disclose your personal data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
Legal Requirements: We may disclose your personal data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency ,or in the good faith belief that such action is necessary (a) to comply with a legal obligation, (b) to protect or defend our rights, interests or property or that of third parties, (c) to prevent or investigate possible wrongdoing in connection with the Services, (d) to act in urgent circumstances to protect the personal safety of Users of the Services or the public; or (e) to protect against legal liability.
Seller Labs’ accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Seller Labs remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Seller Labs proves that it is not responsible for the event giving rise to the damage. Seller Labs is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Section 3 – Security
We maintain reasonable and appropriate security measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
Section 4 – Access Rights
In general, when processing personal data to provide our services, we do so only on behalf of our customers and in accordance with their instructions. This means that if you wish to access any personal data we process on behalf of a Seller Labs customer and request that we correct, amend, delete it if it is inaccurate or processed in violation of Privacy Shield, you should contact that customer with your request. We will then help them to fulfill that request in accordance with their instructions.
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should submit a written request to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Section 5 – Your Choices
You may choose to change personal data or cancel an account by contacting us using the contact details below. You can also unsubscribe from our marketing communications by following the instructions or unsubscribe mechanism in the e-mail message.
We will also provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com.
Section 6 – Questions or complaints
In compliance with the Privacy Shield Principles, Seller Labs commits to resolve complaints about our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact us by email at firstname.lastname@example.org. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of personal data within 45 days of receiving your complaint.
Seller Labs has further committed to refer unresolved privacy complaints to, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus (the “BBB”), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information or to file a complaint. This services of the BBB are provided at no cost to you.
If your Privacy Shield 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 Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Section 7 – How to Contact Us
If you have any questions regarding this Policy or if you need to request access to or update, change or remove personal data that we control, you can do so by contacting us at email@example.com or by regular mail addressed to:
Seller Labs, LLC
1 Press Place,
Athens, GA 30601
Changes to this Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy Shield’s requirements.