LAST UPDATED: May 4, 2018
WireWheel, Inc. (collectively, “WireWheel”, “we”, “our” or “us”) has certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks for Customer Data and Other Information (collectively “Personal Information”) as those terms are defined in the WireWheel Privacy Notice.
This Privacy Shield Notice (“Privacy Shield Notice”) describes our standards and procedures for handling Personal Information transferred from the European Economic Area (“EEA”) and Switzerland to the U.S. in accordance with WireWheel’s obligations under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.
WireWheel 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 of notice, choice, onward transfer, security, data integrity, access, and enforcement (“Principles”) for Personal Information we receive from participating European Countries. Our Privacy Shield certification can be found here.
This Privacy Shield Notice supplements the WireWheel Privacy Notice. Unless specifically defined in this Privacy Shield Notice, the terms in this Privacy Shield Notice have the same meaning as in our WireWheel Privacy Notice. In case of conflict between this Privacy Shield Notice and the Principles, the Principles will govern.
DATA PROCESSED AND PURPOSE
We obtain and process Personal Information from the EEA and Switzerland in different capacities:
- As a data processor, we obtain and process EEA and Swiss Personal Information on behalf of and under the instructions of our customers in connection with the WireWheel Services (“Services”). In this capacity, our customers decide what Personal Information they submit, and we process Personal Information at our customers’ instructions and pursuant to the Services agreements with those customers. We may access this information to provide the Services, to prevent, correct, or address service or technical problems, to respond to customer support matters in response to our customers’ instructions, or to fulfill our contracts with our customers. This information is referred to as “Customer Data” in the WireWheel Privacy Notice.
- As a data controller, we may collect and process EEA and Swiss Personal Information directly from individuals, either via our publicly available website, including www.wirewheel.io or in connection with our customer, partner, and vendor relationships. In this capacity, we process personal information in order to run our business and provide the Services to our customers. This data is referred to as “Other Information” in the WireWheel Privacy Notice.
THIRD PARTIES WITH WHOM WE MAY DISCLOSE PERSONAL INFORMATION
We may disclose Personal Information with a limited number of trusted third party providers who assist us in providing the Services and help us run our business. To date, these third parties are limited to those assisting with technical operations such as hosting, database and security monitoring, customer support, and marketing and analytics operations.
These third parties may only use Personal Information at WireWheel’s instruction and not for their own purposes.
In the case of onward transfer of Personal Information collected under our Privacy Shield Certification to third parties acting on our behalf (as that term is defined in the Principles), WireWheel may have certain liability under the Privacy Shield if the agent processes the personal data in a manner inconsistent with Privacy Shield and WireWheel is responsible for the event giving rise to the damage.
When providing the Services, our customers choose the types of Personal Information that they submit to us and the purposes of the processing. Accordingly, our customers are responsible for providing notice to individuals.
In the event WireWheel is acting as a data controller, WireWheel will provide individuals with choices. To the extent Personal Information is (i) to be used for a purpose that is materially different from the purposes for which the Personal Information was originally collected or subsequently authorized, or (ii) transferred to a third party acting as a data controller, individuals will be given, where practical and appropriate, an opportunity to opt-out of having their Personal Information so used or transferred where it involves non-sensitive information. Where such use or transfer involves sensitive information, individuals must opt-in before such use or transfer.
RIGHT OF ACCESS
Individuals whose data is subject to this Privacy Shield Notice and whose data is submitted directly to us have rights to access Personal Information and may request corrections, deletions, or additions where the Personal Information is inaccurate or has been processed in violation of the Principles. We may limit or deny access to Personal Information where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Principles. These individuals may request access to their Personal Information by contacting us as described below.
When providing our Services, we only process and disclose the Personal Information as specified in our Services agreements with customers. Our customers control how Personal Information is disclosed to us and processed, and how it can be modified. Accordingly, individuals that wish to request access, or to limit use or disclosure of Personal Information that was provided to one of our customers, should contact the company to which they submitted their Personal Information and that use our Services. We will support our customers in responding to these requests.
WireWheel may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
DISPUTE RESOLUTION AND ARBITRATION
In case of disputes, individuals whose data is subject to this Privacy Shield Notice 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 WireWheel is not abiding by this Privacy Shield Notice or is not in compliance with the Principles, he or she should first contact WireWheel at the contact information provided below.
If an issue cannot be resolved through WireWheel’s internal dispute resolution mechanism, individuals may submit a complaint to JAMS, which provides, at no cost to the individual, 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 here. 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.
WireWheel is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”).
This Privacy Shield 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 complaints regarding our privacy practices, or if you would like to exercise your choices or rights, you can contact us:
By email at firstname.lastname@example.org
by mailing to WireWheel, Inc., Attn: Legal, 1310 N. Courthouse Road, Suite 200, Arlington, VA 22201