C Space

EU-US and Swiss-U.S. Privacy Shield: Consumer Privacy Policy

Effective Date: September 23 2016*

Last Updated: December 19, 2017

* This Policy was updated on December 19, 2017 to reference the International Centre for Dispute Resolution-American Arbitration Association (“ICDR-AAA”) but retains its effective date of September 23, 2016

Communispace Corporation (d/b/a C Space) respects your concerns about privacy.

C Space complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. C Space 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 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 privacyshield.gov

This Privacy Shield Policy outlines our general policy and practices for implementing the Privacy Shield Principles for covered Personal Data, and supplements and compliments our main Privacy Policy.

For purposes of this Policy:

“Consumer” means any natural person who is located in the EU or Switzerland, but excludes any individual acting in his or her capacity as an Employee.

“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“EU” means the European Union and Iceland, Liechtenstein and Norway.

“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by C Space in the U.S. from the EU or Switzerland, and (iii) recorded in any form.

“Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield.

“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.

“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings; for individuals in Switzerland, Sensitive Data also includes ideological or trade union-related views or activities, or information on social security measures or administrative or criminal proceedings and sanctions, which are treated outside pending proceedings.

“Supplier” means any supplier, vendor or other third party located in the EU that provides services or products to C Space.

C Space’s Privacy Shield certification, along with additional information about the Privacy Shield, can be found at privacyshield.gov. For more information about our use and processing with respect to information obtained through C Space’s website, please visit the C Space Privacy Policy.

Types of Personal Data C Space Collects

C Space collects Personal Data directly from Consumers. This collection occurs, for example, when a Consumer visits C Space’s website. The company may use this information for the purposes indicated in our Privacy Policy.

The types of Consumer Personal Data C Space collects includes:

C Space also may obtain and use Consumer Personal Data in other ways for which C Space provides specific notice at the time of collection.

C Space’s privacy practices regarding the processing of Consumer Personal Data comply with the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.

Notice

C Space provides information in this Policy and its general Privacy Policy about its Consumer Personal Data practices, including the types of Personal Data C Space collects, the types of third parties to which C Space discloses the Personal Data and the purposes for doing so, the rights and choices Consumers have for limiting the use and disclosure of their Personal Data, and how to contact C Space about its practices concerning Personal Data.

Relevant information also may be found in notices pertaining to specific data processing activities.

Choice

C Space generally offers Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the Privacy Shield Principles, C Space obtains opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact C Space as indicated below regarding the company’s use or disclosure of their Personal Data. Unless C Space offers Consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy.

C Space shares Consumer Personal Data with its affiliates and subsidiaries and with the sponsoring client of a specific community. C Space may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data, (i) to third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. C Space also reserves the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

Accountability for Onward Transfer of Personal Data

This Policy and C Space’s Privacy Policy describe C Space’s sharing of Consumer Personal Data.

Except as permitted or required by applicable law, C Space provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. C Space requires third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and (iii) notify C Space and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Privacy Shield Principles.

With respect to transfers of Consumer Personal Data to third-party Processors, C Space (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the Privacy Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with C Space’s obligations under the Privacy Shield Principles, (v) requires the Processor to notify C Space if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. C Space remains liable under the Privacy Shield Principles if the company’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Privacy Shield Principles, unless C Space proves that it is not responsible for the event giving rise to the damage.

Security

C Space takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

Data Integrity and Purpose Limitation

C Space limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. C Space does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes, C Space takes reasonable steps to ensure that the Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, C Space relies on its Consumers to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers may contact C Space as indicated below to request that C Space update or correct relevant Personal Data.

Subject to applicable law, C Space retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by the Consumer.

Access

Consumers generally have the right to access their Personal Data. Accordingly, where appropriate, C Space provides Consumers with reasonable access to the Personal Data C Space maintains about them. C Space also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. C Space may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer’s privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting C Space as indicated below.

Recourse, Enforcement and Liability

C Space has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. C Space conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions C Space makes about its Privacy Shield privacy practices are true and that C Space’s privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles and Privacy Shield Framework.

Consumers may file a complaint concerning C Space’s processing of their Personal Data. C Space will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Consumers may contact C Space as specified below about complaints regarding C Space’s Consumer Personal Data practices.

In compliance with the Privacy Shield Principles, C Space commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Private Shield policy should first contact C Space at [email protected].

C Space has further committed to refer unresolved Privacy Shield complaints to the International Centre for Dispute Resolution-American Arbitration Association (“ICDR-AAA”), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit http://go.adr.org/privacyshieldfiling.html for more information or to file a complaint. The services of ICDR-AAA are provided at no cost to you.

The mediator may propose any appropriate remedy, such as deletion of the relevant Personal Data, publicity for findings of noncompliance, payment of compensation for losses incurred as a result of noncompliance, or cessation of processing of the Personal Data of the Consumer who brought the complaint. The mediator or the Consumer also may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over C Space. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about C Space’s compliance with the Privacy Shield Principles.

How to Contact C Space

To contact C Space with questions or concerns about this Policy or C Space’s Consumer Personal Data practices please contact [email protected].