SupportYourApp EU-U.S. and Swiss-U.S. Privacy Shield Notice

Effective: May 8, 2018

SupportYourApp, Inc. (“We” or “Our” or “Us”) has certified with the EU-U.S. and Swiss-U.S. Privacy Shield with respect to the personal data we receive and process on behalf of our Clients through providing outsourcing customer support services (the “Services”) under data processing agreements based on the EU Standard Contractual Clauses.

SupportYourApp 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 Clients and/or their customers in participating European countries through the Services, and our Privacy Shield certification will be available here. We may also process personal data to maintain Clients' accounts; respond on Clients' requests and inquiries; and conduct other activities as necessary or appropriate in connection with the servicing and development of the business relationship.

Data Processed

We may process electronic data, text, messages, communications or other materials within the scope of the Services, including without limitation, Personal Data (“Customer Data”) and e-mails, names, phone numbers and other Personal Data provided to us by our potential Clients when they send us request at our e-mails, call us, submit request through special forms on our website (“Client Data”).

Purposes of Data Processing

We process Client Data and Customer Data submitted by Clients and/or their customers for the purpose of providing the Services to Clients and/or responding to Clients’ requests.

Third Parties With Whom We May Share Customer Data

We use a limited number of third party providers to assist us in providing the Services to our Clients. As of the date hereof, these third party providers perform technical operations such as database monitoring, data storage and hosting services and customer support software tools. These third parties may access, process or store personal data in the course of providing these services, but based on our instructions only.

If we receive personal data subject to our certification under the Privacy Shield and then transfer it to a third-party service provider acting as an agent on our behalf, we have certain liability under the Privacy Shield if both (i) the agent processes the personal data in a manner inconsistent with the Privacy Shield and (ii) we are responsible for the event giving rise to the damage.

Questions or Complaints:

If you are a resident of a European country participating in the Privacy Shield and you believe we are not maintaining your personal data within the scope of this Privacy Shield certification, you may direct any questions or complaints concerning our Privacy Shield compliance to privacy@supportyourapp.com or at our mailing address:

SupportYourApp, Inc.
1521 Concord Pike, Suite 301, Wilmington, Delaware 19803
The United States

We will work with you to resolve your issue.

Dispute Resolution

If you are a resident of a European country participating in the Privacy Shield and you have not received a timely response to your concern, or we have not addressed your concern to your satisfaction, you may seek further assistance, at no cost to you, from JAMS, which is an independent dispute resolution body in the United States.

Arbitration

You may also be able to invoke binding arbitration for unresolved complaints 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 JAMS; 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).

Right of Access

Some international Clients and their customers (including those whose personal data is within the scope of this Privacy Shield certification) have certain legal rights to access certain personal data we hold about them and to obtain its correction, amendment or deletion. Those users may exercise some of those rights by sending a request to the relevant Client or us. But please be advised that because our personnel have a limited ability to identify and access an individual user’s personal data that our client has submitted to the Services, if you wish to request access, limit use, or limit disclosure, we may first refer your request to the client who submitted your personal data, and we will support them as needed in responding to your request.

Requirement to Disclose

We may disclose personal data when we have a good faith belief that such an 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.


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