Spot.IM Privacy Shield

Last revised May 5th, 2019.

Spot.IM, Inc. (“Spot.IM US”, “us“, “we” or “our”) has self-certified with the EU-US Privacy Shield and the Swiss-US Privacy Shield Frameworks with respect to the personal data of any individuals residing in the EU or Switzerland that we receive or process, including on behalf of any of our affiliated companies worldwide (collectively, “Spot.IM Group”).

 

Accordingly, Spot.IM US adheres to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework principles as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union and Switzerland to the United States.


If there is any conflict between this Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

1. Scope

Our participation in the Privacy Shield applies to personal data that Spot.IM US receives from and processes on behalf of any other member of the Spot.IM Group, and any customers, business partners, suppliers, employees or candidates of the Spot.IM Group, that reside in the EU or Switzerland.

 

Spot.IM US acts as a sub-processor or processor of the personal data we process on behalf of our customers or any other member of the Spot.IM Group (who are data controllers with respect to the personal data we process on their behalf). 

2. Onward Transfers of Personal Data

We will not transfer personal data originating in the EU or Switzerland to third parties unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of privacy protection to such personal data as required by the Privacy Shield principles. In cases of such onward transfer, Spot.IM US remains responsible and potentially liable, other than for events outside of its reasonable control.

3. Right to Access, Change or Delete Personal Data

EU and Swiss data subjects have the right to access personal data about them, and in some cases to limit use and disclosure of their personal data. If you would like to request access to the personal data we process, please contact privacy@spot.im and provide your name and contact information. If your request pertains to data processed on behalf of another member of the Spot.IM Group, or on behalf of any of our customers, will refer your request to them, and will support them as needed in responding to your request. 

4. Compelled Disclosures

Spot.IM US may be required in certain circumstances to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirement. 

5. Recourse Mechanism

In compliance with the Privacy Shield Principles, Spot.IM US is committed to resolve complaints about our collection or use of personal data. EU and Swiss individuals with inquiries or complaints regarding our Privacy practices should first contact Spot.IM US at privacy@spot.im or by postal mail sent to:

 

Spot.IM, Inc.
Attn: Privacy Shield Inquiry
521 Broadway, Floor 2, New York, NY 10012

 

Spot.IM US has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles and the Swiss-U.S. Privacy Shield Principles to JAMS, a non-profit alternative dispute resolution provider located in the United States to assist with the complaint resolution process. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint. The services of JAMS are provided at no cost to you. 

6. Enforcement

Spot.IM US is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) to ensure compliance with the EU-US Privacy Shield Principles and the Swiss-US Privacy Shield Principles outlined in this Notice. 

7. Arbitration

Under certain conditions, more fully described on the Privacy Shield website, you may also be able to invoke binding arbitration when other dispute resolution procedures have been exhausted.