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Jifflenow Privacy Shield Notice

Jifflenow Privacy Shield Notice

Last Updated: June 14, 2019

iPolipo, Inc. dba Jifflenow (“Jifflenow”) (“We” or “Our”) 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 customers in the European Union, the European Economic Area, and Switzerland, through our Services. Unless not defined in this Jifflenow Privacy Shield Notice, capitalized terms will have the same meaning as ascribed to them in our Terms of Use and Privacy Policy.

Jifflenow complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth 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, respectively. Jifflenow has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy notice, the Jifflenow Privacy Policy or the Terms of Use and the Privacy Shield Principles, 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/.

Jifflenow 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 customers in participating European countries through the Services, and our Privacy Shield certification will be available here. We may also process personal data our customers submit relating to individuals in the EU and Swiss via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses.

Notwithstanding anything to the contrary herein or in the Privacy Policy, pursuant to the Privacy Shield, Jifflenow remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.”

Data Processed

We provide the Services so that our customers can communicate and operate aspects of their businesses.  In providing these Services, we process data our customers submit to the Services or instruct us to process on their behalves in connection with the Services (“Customer Data”).

Purposes of Data Processing

We process Customer Data submitted by customers for the purpose of providing the Services to customers. To fulfill these purposes, we may access data to provide the Services, to prevent or address service or technical problems, to respond to customer support matters, to follow the instructions of our customer who submitted the data, or in response to contractual requirements with our customers. We will offer you the opportunity to opt-out before your personal information is used for purposes not listed here or in the Privacy Policy.

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 customers. 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 you wish to opt-out of services, or delete or deactivate services of any of our third party providers, please send us an email request at privacy@jifflenow.com. Please note that such an opt-out, delete, or deactivation will impact your enjoyment of our Services.

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 are potentially liable 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

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

privacy@jifflenow.com or at our mailing address:

iPolipo, Inc.

1330 S Bascom Ave, Suite C, 

San Jose, CA 95128.

We will work with you to resolve your issue.

Dispute Resolution

Jifflenow 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.

We also commit to cooperate with competent EU data protection authorities (DPAs) with regard to our customers end users’ human resources data transferred from a European country participating in the Privacy Shield in the context of the employment relationship.

If your complaint involves human resources data transferred to the United States from the EU and/or Switzerland in the context of the employment relationship, and Jifflenow does not address it satisfactorily, Jifflenow commits to cooperate with the panel established by the EU data protection authorities (DA Panel) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable and to comply with the advice given by the DPA panel and/or Commissioner, as applicable with regard to such human resources data.  To pursue an unresolved human resources complaint, you should contact the state or national data protection or labor authority in the appropriate jurisdiction.  Complaints related to human resources data should not be addressed to the BBB EU PRIVACY SHIELD. Contact details for the EU data protection authorities can be found at: http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm.

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 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).

Right of Access

EU and Swiss users have 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 through the options described in our Privacy Policy. But please be advised that because our personnel have a limited ability to identify and access an individual user’s personal data that our customer has submitted  the Services, if you wish to request access, to limit use, or to limit disclosure, we may first refer your request to the customer who submitted your personal data, and we will support them as needed in responding to your request.

Jifflenow 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 privacy@jifflenow.com. 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.