EU-U.S. Privacy Shield Privacy Notice
Effective Date: October 16, 2017
Elementum Ltd. (“Elementum”) self-certifies under the EU-U.S. Privacy Shield (the “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from all European Union member countries. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.
Types of personal data collected
Elementum collects personal data from (i) individual users affiliated with our corporate customers who register accounts with us, or who log into and use our services via our website and mobile applications ("EU Users"), (ii) visitors to our website who request information about Elementum products and services, leave feedback, seek employment, request support (“EU Website Visitors”) and (iii) Elementum employees and contractors resident in the European Union (“EU Employees”).
Elementum may collect the following types of personal data from EU Users, EU Website Visitors and EU Employees:
Commitment to subject to the Principles
We subject to the Principal of the Privacy Shield all personal data that we receive from individuals and companies in the European Union in reliance on the Privacy Shield. We also receive some data in reliance on other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses.
Purposes of collection and use
Elementum collects and uses personal data of EU Users for the purposes of:
aggregating data to be used in anonymized analysis, marketing content, and other business purposes, and
Elementum collects and uses personal data of EU Website Visitors for the purposes of:
responding requests from the EU Website Visitor for support, employment, information about Elementum products and services, or other requests
responding to feedback given by the EU Website Visitor, and
other purposes disclosed at the time of collection.
Elementum collects and uses personal data of EU Employees for the purposes of:
Type of third parties to which we disclose personal data and purposes
Elementum may share personal data we collect from individuals or companies in the European Union with the following types of third parties and for the following purposes:
Right to access
If EU Users, EU Website Visitors or EU Employees have any questions regarding this Privacy Shield Notice or need to update, change or remove information, please contact [firstname.lastname@example.org]. Elementum will respond to your request to access or delete your information within 15 days.
Choices and means
If you are an EU User or EU Website Visitor, if at any time after registering for information, your personal data changes, you change your mind about receiving information from us, wish request that Elementum no longer use your information to provide you services, contact us via the contact information in the “Right to Access” section above. If you are an EU Employee, if at any time your personal data changes, or your privacy preferences change, contact us via the contact information in the “Right to Access” section above and we will update your information and take reasonable steps to accommodate your preferences.
You may choose to unsubscribe from our marketing communications by following the instructions or unsubscribe mechanism in the message you received. We will retain and use your information for as long as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.
Independent dispute resolution body
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://www.jamsadr.com/eu-us-privacy-shield].
Investigatory and enforcement powers of the Federal Trade Commission
Elementum is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission with regard to Elementum’s compliance with this policy and the Privacy Shield.
If you are located in the European Union and have exhausted all other means to resolve your concern regarding a potential violation of Elementum’s obligations under the Privacy Shield, you may seek resolution via binding arbitration. For additional information about the arbitration process please visit the Privacy Shield website: www.privacyshield.gov.
Requirement to disclose
Elementum may disclose personal data in special cases when we have a good faith belief that such action is necessary to: (a) conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; (b) protect and defend our rights or property; or (c) act to protect the interests of our users or others.
Liability in cases of onward transfers
If a third party service provider providing services on Elementum’s behalf processes personal data from the European Union in a manner inconsistent with the Privacy Shield, Elementum will be liable unless we can prove that we are not responsible for the event giving rise to the damages.