EU-U.S. and Swiss-U.S. Privacy Shield Policy Notice
We use reasonable and appropriate physical, electronic, and administrative safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the nature of the Personal Data and the risks involved in processing that information.
Access to Personal Data
You may contact us at firstname.lastname@example.org to review, correct, or delete any personal data. We may limit or deny access to Personal Data where providing such access is unreasonably burdensome, expensive under the circumstances, or as otherwise permitted by the Privacy Shield Principles.
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.
Third-Party Data Sharing
Questions or Complaints:
If you are a resident of a European country participating in the Privacy Shield and you believe we do not maintain 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@Smart.ly or contact us at our mailing address:
3000 K St NW Ste 275
Washington, DC 20007
We will work with you to resolve your issue.
In the event we are unable to resolve your concern, you may contact JAMS, which provides an independent third-party dispute resolution body based in the United States, and they will investigate and assist you free of charge. A binding arbitration option may also be available to you in order to address residual complaints not resolved by any other means.
You may also be able to invoke binding arbitration for unresolved complaints, but prior to initiating such arbitration, a resident of Switzerland or 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).
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.
Changes to This Policy