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

Pedago, LLC. (“We” or “Our”) 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 customers through our online platform (the “Services”). Pedago certifies that it adheres to the Privacy Shield Principles for Personal Data received from entities in the European Economic Area (the “EEA”) and Switzerland. This Privacy Shield Policy, in conjunction with our Privacy Policy (available here) describe the privacy practices we implement for any customer data collected worldwide. This Privacy Shield Policy uses terms defined in our general Privacy Policy. 

To learn more about the Privacy Shield program visit  www.privacyshield.gov, and to view our certification, please visit https://www.privacyshield.gov/list.

Data Collected

We only collect Personal Data that is relevant to providing our Services. Examples of the types of personal data collected can be found in our full privacy policy. We take reasonable steps to ensure that the Personal Data received under the Privacy Shield is needed for Pedago’s Services, and that it is accurate, complete, and current based on the information you have provided to us.

Data Security

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  privacy@smart.ly 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

We may share your data with a limited number of third-party providers as outlined in our privacy policy. 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 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:

Pedago, LLC
3000 K St NW Ste 275
Washington, DC 20007

We will work with you to resolve your issue.

Dispute Resolution

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.

Arbitration

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

We may make changes to this policy from time to time in conjunction with our privacy policy and in compliance with the Privacy Shield. You can refer to the most recent revision date (labeled as "Last updated on") at the bottom of this policy.

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