Last Updated: September 30, 2016 IPWebMedia Corp. (“IPWebMedia”) respects your concerns about privacy. IPWebMedia participates in the EU-U.S. Privacy Shield (“Privacy Shield”) framework issued by the U.S. Department of Commerce. IPWebMedia commits to comply with the Privacy Shield Principles with respect to Consumer Personal Data the company receives from the EU in reliance on the Privacy Shield. This Policy describes how IPWebMedia implements the Privacy Shield Principles for Consumer Personal Data.
For purposes of this Policy: “Client” means any entity that purchases or otherwise obtains products or services from IPWebMedia. “Consumer” means any natural person who is located in the EU, but excludes any individual acting in his or her capacity as an Employee.
“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
“Employee” means any current, former or prospective employee of IPWebMedia, or any of its European affiliates, who is located in the EU.
“EU” means the European Union and Iceland, Liechtenstein and Norway.
“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by IPWebMedia in the U.S. from the EU, and (iii) recorded in any form.
“Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield.
“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.
Types of Personal Data IPWebMedia Collects IPWebMedia collects Personal Data directly from Consumers. This collection occurs, for example, when a Consumer visits IPWebMedia’s website and provides Personal Data to IPWebMedia. Click here for information on the types of Personal Data IPWebMedia receives through its website. In addition, IPWebMedia obtains Consumer Personal Data, such as contact information, in connection with maintaining its Client relationships and providing its products and services to Clients. IPWebMedia also obtains Personal Data, such as contact information, of its vendors’ representatives. IPWebMedia uses this information to manage its relationships with its vendors.
As a Processor, IPWebMedia receives Personal Data about its Clients’ Consumers located in the EU. IPWebMedia’s Clients provide the Personal Data to IPWebMedia in connection with IPWebMedia’s provision of services to its Clients. In this capacity, IPWebMedia acts pursuant to its Clients’ instructions. The types of Personal Data IPWebMedia’s Clients provide include names, postal addresses, email addresses, phone numbers and social media interactions. IPWebMedia processes Consumer Personal Data in the U.S. to provide products and services to its Clients. IPWebMedia’s privacy practices regarding the processing of Consumer Personal Data comply, as appropriate, with the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.
Security IPWebMedia takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data. Data Integrity and Purpose Limitation IPWebMedia limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. IPWebMedia does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes and consistent with its role as a Controller or Processor, IPWebMedia takes reasonable steps to ensure that the Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, IPWebMedia relies on its Consumers and Clients (with respect to Personal Data of Consumers with whom IPWebMedia does not have a direct relationship) to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers (and Clients, as appropriate) may contact IPWebMedia as indicated below to request that IPWebMedia update or correct relevant Personal Data. Subject to applicable law, IPWebMedia retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by the Consumer or Client, as appropriate.
Access Consumers generally have the right to access their Personal Data. Accordingly, to the extent IPWebMedia acts as a Controller, where appropriate, IPWebMedia provides Consumers with reasonable access to the Personal Data IPWebMedia maintains about them. IPWebMedia also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. IPWebMedia may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer’s privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting IPWebMedia as indicated below.
When IPWebMedia maintains Personal Data about Consumers with whom IPWebMedia does not have a direct relationship because IPWebMedia maintains the Consumers’ data as a Processor for its Clients, IPWebMedia’s Clients are responsible for providing Consumers with access to the Personal Data and the right to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. In such circumstances, Consumers should direct their questions to the appropriate IPWebMedia Client. When a Consumer is unable to contact the appropriate Client, or does not obtain a response from the Client, IPWebMedia will provide reasonable assistance in forwarding the Consumer’s request to the Client. Recourse, Enforcement and Liability
IPWebMedia has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. IPWebMedia conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions the company makes about its Privacy Shield privacy practices are true and that the company’s privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles. Consumers may file a complaint concerning IPWebMedia’s processing of their Personal Data. IPWebMedia will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Consumers may contact IPWebMedia as specified below about complaints regarding the company’s Consumer Personal Data practices.
If a Consumer’s complaint cannot be resolved through IPWebMedia’s internal processes, IPWebMedia will cooperate with JAMS pursuant to the JAMS International Mediation Rules, available on the JAMS website at https://www.jamsadr.com/eu-us-privacy-shield. JAMS mediation may be commenced as provided for in the relevant JAMS rules. Following the dispute resolution process, JAMS or the Consumer may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over IPWebMedia. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about IPWebMedia’s compliance with the Privacy Shield Principles. When IPWebMedia maintains Personal Data about Consumers with whom IPWebMedia does not have a direct relationship because IPWebMedia obtained or maintains the Consumers’ data as a Processor for its Clients, Consumers may submit complaints concerning the processing of their Personal Data to the relevant Client, in accordance with the Client’s dispute resolution process. IPWebMedia will participate in this process at the request of the Client or the Consumer.
How to Contact IPWebMedia To contact IPWebMedia with questions or concerns about this Policy or IPWebMedia’s Consumer Personal Data practices: