Echo360 and its affiliated and subsidiary entities comply with the EU-US Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Data transferred from the European Union to the United States. Echo360 has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access and Recourse, Enforcement and Liability. To learn more about the Privacy Shield Program, and to view our certification, please visit https://www.privacyshield.gov/.
Echo360’s participation in the Privacy Shield applies to Personal Data received in the United States from European Union (“EU”) customers and users of the Web Site and Services.
Echo360 complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, including the onward transfer liability provisions. Echo360 ensures that all such third parties receive information only as described in the Section entitled “Disclosure to Third Parties” and shall remain liable for any loss, claim or damage (“Loss”) arising from such Personal Data transferred to an Echo360 third party acting as an agent on Echo360’s behalf, except to the extent Echo360 can show it was not responsible for the events giving rise to the Loss.
Under the Privacy Shield, you have an opportunity to opt out of Echo360’s collection of Personal Data where (i) Echo360 discloses your information to a third party, or (ii) where information will be used in a manner materially different from that which it was originally collected. For the avoidance of doubt, Echo360 will not provide “choice” when disclosure is made to a third party that is acting as an agent to perform task(s) on behalf of Echo360. Echo360 shall always enter into a contract with such agent to protect the confidentiality and security of your Personal Data, as more thoroughly described below.
If you wish to opt-out of Echo360’s collection of your Personal Data, please reach out to the Privacy Officer listed herein below. Should you request access to, opt-out of, or revoke your consent to our collection of Personal Data, as set forth above, Echo360 may request that you provide certain information in order to confirm your identity with respect to the request. Please allow Echo360 a reasonable amount of time to comply with your request and for such request to take effect.
Echo360 does not collect any Sensitive Personal Data. Sensitive Personal Data means any information revealing race, ethnic origin, sexual orientation, political opinions or affiliations, religious beliefs, national identification and health. However, in the event the particular Services provided to you should require such collection of Sensitive Personal Data, you shall have a right to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or you subsequently authorized.
With respect to Personal Data received or transferred pursuant to the Privacy Shield, Echo360 is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Echo360 may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Echo360 has committed to refer any complaints regarding your Personal Data that have not been resolved after contacting the Echo360 Privacy Officer, as described in “Privacy Related Inquiries and Complaints,” to a dispute resolution provider. Echo360 has appointed the International Centre for Dispute Resolution (“ICDR”), a division of the American Arbitration Association (“AAA”), located in the United States, as its independent dispute resolution provider. If you do not receive timely acknowledgement for your complaint from Echo360, or if Echo360 has not addressed your complaint to your satisfaction, please contact or visit AAA at www.icdr.org for more information or to file a complaint. The services of AAA/ICDR are provided at no cost to you.
In limited circumstances, it may be possible for you to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms.