Last Updated: April 1st, 2018
PayKickstart LLC and its U.S. controlled subsidiaries (collectively, “PayKickstart”, “we”, “our” or “us”) respect your privacy. This Privacy Shield Notice (“Notice”) describes our standards and procedures regarding Personal Information transferred from the European Economic Area (“EEA”) and Switzerland to the U.S. in accordance with PayKickstart’s obligations under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.
PayKickstart has subscribed to and will adhere to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks by adopting and implementing the Privacy Shield Principles (“Principles”). More information about the Privacy Shield can be found at www.privacyshield.gov. Our Privacy Shield certification can be found at www.privacyshield.gov/list.
For the purpose of this Notice, “Personal Information” means any data relating to an identified or identifiable individual, including, for example, name, address, telephone number and e-mail address, and “processing” means any operation performed on Personal Information, such as, for example, collection, use, management, consultation or disclosure.
This Notice 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.)
This notice supplements our PayKickstart privacy statement. Unless specifically defined in this notice, the terms in this notice have the same meaning as in our privacy statement. In case of conflict between this notice and the principles, the principles will govern.
HOW WE COLLECT PERSONAL INFORMATION
We obtain and process Personal Information from the EEA and Switzerland in different capacities.
As a data controller, we collect and process EEA and Swiss Personal Information directly from individuals, either via our publicly available websites, www.PayKickstart.com , or in connection with our customers, vendors, joint venture partners, and other marketing partners.
As an agent (as that term is used in the Principles), we obtain and process EEA and Swiss Personal Information on behalf of and under the instructions of our customers in connection with the online services PayKickstart provides (“Services”). In that context, customers are the data controllers or agents and the roles and responsibilities of the parties for the processing of Personal Information are defined in our agreements with customers.
PayKickstart commits to comply with the Principles with respect to all Personal Information received from the EEA and Switzerland in reliance on the Privacy Shield.
PRIVACY SHIELD PRINCIPLES
We take reasonable steps to limit the collection and usage of Personal Information to that which is relevant for the purposes for which it was collected, and to ensure that such Personal Information is reliable, accurate, complete and current. Individuals are encouraged to keep their Personal Information with PayKickstart up to date and may contact PayKickstart as indicated below or in the PayKickstart Privacy Statement to request that their Personal Information be updated or corrected.
We will retain your Personal Information in an identifiable form only for the period necessary to fulfill the purposes outlined in the PayKickstart Privacy Statement, unless a longer retention period is required or permitted by law or by the Principles. We will adhere to the Principles for as long as we retain the Personal Information collected under the Privacy Shield.
When providing our Services, we process and retain Personal Information as necessary to provide our services as permitted in our agreement with customers, or as required or permitted under applicable law.
We remain responsible for the processing of Personal Information received under the Privacy Shield and subsequently transferred to a third party acting as an agent if the agent processes such Personal Information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.
When providing our Services, we only process and disclose the Personal Information as specified in our agreements with customers. Our customers controls how Personal Information is disclosed to us and processed, and how it can be modified. Accordingly, if you want to request access, or to limit use or disclosure of your Personal Information, please contact the company to which you submitted your Personal Information and that uses our Services. If you contact us with the name of our customer to which you provided your Personal Information, we will refer your request to that customer and support them in responding to your request.
In case of disputes, individuals are able to seek resolution of their questions or complaints regarding the processing of their Personal Information in accordance with the Principles. If an individual feels that PayKickstart is not abiding by this Notice or is not in compliance with the Principles, he or she should first contact PayKickstart at the contact information provided below.
If an issue cannot be resolved through PayKickstart’s internal dispute resolution mechanism, you may submit a complaint to JAMS, which provides, at no cost to you, an independent third-party dispute resolution option based in the U.S. To contact JAMS and/or learn more about the company’s dispute resolution services, including instructions for submitting a complaint, please visit https://www.jamsadr.com/eu-us-privacy-shield. For residual complaints not fully or partially resolved by other means, you may be able to invoke binding arbitration as detailed in the Principles available here.
PayKickstart is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”).
RENEWAL AND VERIFICATION
PayKickstart will renew its US-EU Privacy Shield and Swiss-US Privacy Shield certifications annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.
Prior to the re-certification, we will conduct an in-house verification to ensure that its attestations and assertions about its treatment of Personal Information are accurate and that the we have appropriately implemented these practices.
This Notice may be amended consistent with the requirements of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. When we update this Notice, we will also revise the “Last Updated” date at the top of this document.
QUESTIONS OR COMPLAINTS
If you have any questions, concerns or complaint regarding our privacy practices, or if you’d like to exercise your choices or rights, you can contact us:
By email at Support@PayKickstart.com
By regular mail to PayKickstart LLC, Attn: Mark Thompson, PO Box 555, Wake Forest, NC 27588, USA
Talk to a knowledgeable product specialist to learn more about your requirements and ensure PayKickstart is the perfect fit for your needs.
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