PRIVACY SHIELD POLICY

Updated June 18, 2018

4me, Inc. (“4me,” “we,” “us,” “our,” or the “Company”) has certified its 4me Services, for which 4me acts as a data processor, under the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. 4me 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 Shield Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  We may also process personal data that our customers submit relating to individuals in the EU, via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Scope

4me delivers the 4me Services that allow an organization’s internal and external service providers to collaborate seamlessly, while the level of service that each party provides is visible in real time. 4me adheres to the principles of the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework with respect to personal data submitted by customers of 4me to the 4me Services, in accordance with the Privacy Shield.

Data processed

4me provides software as a service that our customers use to operate aspects of their businesses. In providing the 4me Services, 4me processes data that our customers submit to our services or instruct us to process on their behalf. While 4me’s customers decide what data to submit, it typically includes information about their customers, partners, vendors, prospects, employees, and users of their tools and applications.

Purposes of data processing

4me processes data submitted by customers for the purpose of providing 4me’s online services to its customers. To meet these purposes, 4me may access the data to provide the services, to correct and address technical or service related problems, or to follow instructions of the 4me customer who submitted the data, or in response to contractual requirements.

Questions or complaints

If you are a resident of a European country participating in the Privacy Shield and you believe we 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@4me.com or at our mailing address:

4me, Inc.
Attn: Data Protection Officer
555 Bryant Street #156
Palo Alto, CA 94301
U.S.A.

We will work with you to resolve your issue.

Dispute Resolution

If you are a resident of a European country participating in the Privacy Shield and you have not received timely response to your concern, or we have not addressed your concern to your satisfaction, you may seek further assistance, at no cost to you, from JAMS, which is an independent dispute resolution body in the United States. Please contact or visit the JAMS website at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint.

Arbitration

You may also be able to invoke binding arbitration for unresolved complaints but prior to initiating such arbitration, a resident of 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.

Third parties who may receive personal data

4me uses a limited number of third-party service providers to assist us in providing our services to customers. These third-party providers may offer customer support to our customers, perform network monitoring and other technical operations, assist with the transmission of data, and provide data storage services. These third parties may access, process, or store personal data in the course of providing their services. 4me maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our Privacy Shield obligations, and 4me may be liable if they fail to meet those obligations and we are responsible for the event giving rise to damage.

Your rights to access, to limit use, and to limit disclosure

EU individuals and Swiss individuals have rights to access personal data about them, and to limit use and disclosure of their personal data. With our Privacy Shield certification, 4me has committed to respect those rights. Because personnel of 4me have limited ability to access data that our customers submit to our services, if you wish to request access, to limit use, or to limit disclosure, please provide the name of the 4me customer who submitted your data to our services. We will refer your request to that customer, and, will support them as needed in responding to your request.

U.S. Federal Trade Commission enforcement

4me’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Compelled disclosure

4me may be required to disclose personal data 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.