Privacy Shield Notice - Popular Pays

Last modified: December 14, 2018

Privacy Shield Notice

Popular Pays, Inc. (“Company” or “We”) have certified with the EU-U.S. and Swiss-U.S. Privacy Shield (the “Privacy Shield”) with respect to the personal data we receive and process on behalf of our users in the European Union, the European Economic Area, and Switzerland, through our Services and Platform. Unless defined in this Privacy Shield Notice, capitalized terms will have the same meaning as ascribed to them in our Creator Terms and Conditions, Privacy Policy, or Master Campaign Agreement, as applicable.

Company complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework and the Principles adopted by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union and Switzerland to the United States, pursuant to the Privacy Shield. Company has certified to the Department of Commerce that it adheres to the Privacy Shield Principles and Frameworks. If there is any conflict between the terms in this Privacy Policy Notice, the Company’s Creator Terms and Conditions, Privacy Policy, or Master Campaign Agreement, as applicable, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Company certifies that it adheres to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement for personal data submitted by our users in participating European countries and Switzerland through the Services, and our Privacy Shield certification will be available here. We may also process personal data our users submit relating to individuals in the EU and Switzerland via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses.

Data Processed
In providing these Services, we process Personal Data that users submit to us or instruct us to process on their behalves in connection with the Services (“User Data”) as fully described in our Privacy Policy, that is accessible here.

Purposes of Data Processing
We process User Data submitted by users for the purpose of providing the Services to users. To fulfill these purposes, we may access such User Data to provide the Services, to prevent or address service or technical problems, to respond to user requests , to follow the instructions of our user who submitted the data, or in response to contractual requirements with our users. We will offer you the opportunity to opt-out before your Personal Data is used for purposes not listed here or in the Privacy Policy.

Third Parties With Whom We May Share User Data
We use a limited number of third party providers to assist us in providing the Services to our users. These third-party providers perform technical operations such as database monitoring, data storage and hosting services and user support software tools.

These third parties may access, process or store Personal Data in the course of providing these support services, but based on our instructions only. If you wish to opt-out of such services, or delete or deactivate services of any of our third party providers, please send us an email request at [email protected] Please note that such an opt-out, delete, or deactivation may impact your continued use of our Services. We acknowledge that, pursuant to the Privacy Shield, we may be liable for the appropriate transfer of EU and Swiss personal data to third parties unless we can prove that we were not a party to the injury.

Right of Access Under the Privacy Shield Frameworks
Company acknowledges that EU and Swiss individuals have the right to access the personal information that we maintain about them. An EU or Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to [email protected] If requested to remove data, we will respond within a reasonable timeframe.

Requirement to Disclose
We may disclose personal data when we have a good faith belief that such action is necessary to: conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; or to enforce our contractual obligations.

Questions or Complaints:
In compliance with the EU-US and Swiss-US Privacy Shield Principles, Company commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Company at:

[email protected] or 130 S Jefferson St, 4th Floor Chicago, IL 60661

We will work with you to resolve your issue.

Dispute Resolution
Company has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Arbitration
You may also be able to invoke binding arbitration for unresolved complaints before a Privacy Shield Panel but prior to initiating such arbitration, a resident of a European country participating in the Privacy Shield must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from BBB PRIVACY SHIELD; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.

U.S. Federal Trade Commission Enforcement
Our Privacy Shield compliance is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).