E.U. – U.S. and Swiss-US Privacy Shield Policy

Effective day Dec 1 2017

We, Wootric, Inc., are committed to protecting your privacy. This Policy sets out the privacy principles we follow with respect to transfers of personal data from the European Economic Area (“EEA”) to the United States, including personal data we receive from individuals residing in the EEA who visit our web and mobile sites or apps and/or who use any of our services or otherwise interact with us (“you”).

We adhere to the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the European Commission and the US Department of Commerce regarding the collection, use and retention of personal data from European Union member countries. Wootric, Inc. has certified adherence to and commits to apply the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. If there is any conflict between the terms in this privacy policy(ies) 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/.

For purposes of enforcing compliance with the Privacy Shield, we are subject to the investigatory and enforcement authority of the US Federal Trade Commission.

For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov . To review our certification on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: https://www.privacyshield.gov/list .

Types of personal data we collect and use

Our online privacy policy located at https://www.wootric.com/company/privacy/ describes the categories of personal data we may receive in the United States, as well as the purposes for which we use that personal data. We will only process personal data in ways that are compatible with the purpose we collected it for, or for the purposes you later authorize. Before we use your personal data for a purpose that is materially different from the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt-out. We maintain reasonable procedures to help ensure that personal data we collect and use is reliable for its intended use, accurate, complete, and current.

Data transfers to third parties

• Agents, consultants and service providers: We may share your personal data with our contractors and service providers who process personal data on our behalf to perform certain business-related functions. These companies include database service providers, backup and disaster recovery service providers, email service providers and others. When we engage another company to perform such functions, we may provide them with information, including personal data, in connection with their performance of such functions.
• With regard to the Principle of Accountability for Onward Transfer, Wootric will remain potentially liable in cases of onward transfer if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
• Our Group Companies: We may also share your personal data with our parent companies, subsidiaries and/or affiliates for purposes consistent with this Policy.
• Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets.
• Disclosures for National Security or Law Enforcement: Under certain circumstances, we may be required to disclose your personal data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
• Legal Requirements: We may disclose your personal data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency ,or in the good faith belief that such action is necessary (a) to comply with a legal obligation, (b) to protect or defend our rights, interests or property or that of third parties, (c) to prevent or investigate possible wrongdoing in connection with the Services, (d) to act in urgent circumstances to protect the personal safety of Users of the Services or the public; or (e) to protect against legal liability.

Security

We maintain reasonable and appropriate security measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

Access Rights

In general, when processing personal data to provide our services, we do so only on behalf of our customers and in accordance with their instructions. This means that if you wish to access any personal data we process on behalf of a Wootric customer and request that we correct, amend, delete it if it is inaccurate or processed in violation of Privacy Shield, you should contact that customer with your request. We will then help them to fulfil that request in accordance with their instructions.

Where we process personal data collected via our website or via our services for our own account management, billing or marketing purposes, you have the right to access personal data that we hold about you and request that we correct, amend, delete it if it is inaccurate or processed in violation of Privacy Shield. These access rights may be limited in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your personal data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

Your Choices

You may choose to change personal data or cancel an account by contacting us using the contact details below. You can also unsubscribe from our marketing communications by following the instructions or unsubscribe mechanism in the e-mail message.

Questions or complaints

You can direct any questions or complaints about the use or disclosure of your personal data to us at support@wootric.com. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of personal data within 45 days of receiving your complaint.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact the Council of Better Business Bureaus, our US-based third party dispute resolution provider (free of charge). To find out more, go to http://www.bbb.org/eu-privacy-shield/for-eu-consumers

Binding Arbitration

You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with us and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. To find out more about the Privacy Shield’s binding arbitration scheme please see www.privacyshield.gov/article?id=My-Rights-under-Privacy-Shield .

How to Contact Us

If you have any questions regarding this Policy or if you need to request access to or update, change or remove personal data that we control, you can do so by contacting us at support@wootric.com or by regular mail addressed to:

Wootric, Inc.
Attn: Legal
220 27th^th St
San Francisco,
CA 94131
United States

Changes to this Policy

We reserve the right to amend this Policy from time to time consistent with the Privacy Shield’s requirements.