Eldrea Daring Media LLC complies with the U.S. Privacy Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information.
All Eldrea Daring Media LLC Employees who handle Personal Data are required to comply with the Principles stated in this Policy.
This Policy applies to the processing of Customers Personal Data and/or HR data that Eldrea Daring Media LLC receives in the United States concerning customers’ US human resource data.
2. RESPONSIBILITIES AND MANAGEMENT
Eldrea Daring Media LLC has designated its Legal Department to oversee its information security program, including its compliance with the Privacy program. The Legal Department shall review and approve any material changes to this program as necessary.
Eldrea Daring Media LLC will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. Eldrea Daring Media LLC personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 5 for a discussion of the steps that Eldrea Daring Media LLC has undertaken to protect Personal Data.
3. COLLECTION AND USE OF PERSONAL DATA
Eldrea Daring Media LLC provides various solutions to its customers, which are predominantly business Customers, and collects some Personal Data from Customers when they purchase our products, request information from Eldrea Daring Media LLC, or otherwise communicate with Eldrea Daring Media LLC. For example, Eldrea Daring Media LLC’s Customers may choose to seek live support or request transactional data concerning a product.
The Personal Data that Eldrea Daring Media LLC collects may vary based on the Customers and their specific request for the product. As a general matter, Eldrea Daring Media LLC may collect the following types of Personal Data from its Customers: contact information, including, a contact person’s name, work email address, work mailing address, work telephone number, title, and company name, as well as payment information (which might include credit card and/or bank account information)
The information collected from Eldrea Daring Media LLC’s Customers in this capacity is used for managing transactions, reporting, invoicing, renewals, other operations related to providing product to the Customer, and as otherwise requested by the Customer.
4. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA
Except as otherwise provided herein, Eldrea Daring Media LLC discloses Personal Data only to a Third Party who reasonably needs to know such data. Such recipients must agree to abide by confidentiality obligations. Eldrea Daring Media LLC may provide Personal Data to a Third Party that acts as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, Eldrea Daring Media LLC may store such Personal Data in the facilities operated by a Third Party. Such Third-Party must agree to use such Personal Data only for the purposes for which they have been engaged by Eldrea Daring Media LLC and they must either: (1) comply with the Privacy protection mechanism permitted by the applicable data protection law(s) for transfers and processing of Personal Data; or (2) agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy. Eldrea Daring Media LLC also may disclose Personal Data for other purposes or to another Third-Party when a Data Subject has consented to or requested such disclosure.
5. DATA INTEGRITY AND SECURITY
Eldrea Daring Media LLC uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. Eldrea Daring Media LLC has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to Eldrea Daring Media LLC’s electronic information systems requires user authentication via password or similar means. Eldrea Daring Media LLC also employs access restrictions, limiting the scope of employees who have access to Customer Personal Data. Further, Eldrea Daring Media LLC uses secure encryption technology to protect certain categories of Personal Data. Despite these precautions, no data security safeguards can guarantee absolute security all of the time, and as such Eldrea Daring Media LLC does not make any such guarantee.
6. ACCESSING PERSONAL DATA
Eldrea Daring Media LLC personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
7. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
7.1 Right to Access. Data Subjects have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which Eldrea Daring Media LLC
collected the Personal Data. Data Subjects may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law. Upon reasonable request and as required by the Privacy Principles, Eldrea Daring Media LLC allows Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Customers may edit their Personal Data by contacting Eldrea Daring Media LLC by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request the erasure of Personal Data, Customers should submit a written request of the same.
7.2 Requests for Personal Data. Eldrea Daring Media LLC will track each of the following and will provide notice to the appropriate parties under the law and contract when either of the following circumstances arises: (a) legally binding
request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If Eldrea Daring Media LLC receives a request for access to his/her Personal Data
from a Customer’s customer, then, unless otherwise required under law or by contract with such Customer, Eldrea Daring Media LLC will refer such Data Subject to Customer.
7.3 Satisfying Requests for Access, Modifications, and Corrections. Eldrea Daring Media LLC will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.
8. CHANGES TO THIS POLICY
This Policy may be amended from time to time, consistent with the applicable data protection and privacy laws and principles. Eldrea Daring Media LLC will make Employees aware of changes to this policy and will notify Customers if any changes are made that materially affect the way that Personal Data is handled and previously collected, and Eldrea Daring Media LLC will allow Customers to choose whether their Personal Data may be used in any materially different manner.
9. QUESTIONS OR COMPLAINTS
Customers may contact Eldrea Daring Media LLC with questions or complaints concerning this Policy at firstname.lastname@example.org
10. ENFORCEMENT AND DISPUTE RESOLUTION
Eldrea Daring Media LLC
5105 W Parker Avenue
Chicago, IL 60639, USA
We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your US Personal Data within 45 days of receiving your inquiry or complaint. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit your countries DPA for more information or to file a complaint.
Capitalized terms in this Policy have the following meanings:
“Customer” means a prospective, current, or former partner (distributor or reseller), vendor, supplier, customer, or client of Eldrea Daring Media LLC. The term also shall include any individual agent, employee, representative, customer, or client of an Eldrea Daring Media LLC Customer where Eldrea Daring Media LLC has obtained his or her Personal Data from such Customer as part of its business relationship with the Customer.
“Data Subject” means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal, physical, psychological, mental, economic, cultural, or social characteristics.
“Employee” means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of Eldrea Daring Media LLC or any of its affiliates or subsidiaries, who is also a resident of a country.
“Personal Data” means data that personally identifies or may be used to personally identify a person, including an individual’s name in combination with the country of birth,
marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, email address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available.
“Third Party” means any individual or entity that is neither Eldrea Daring Media LLC nor Eldrea Daring Media LLC employee, agent, contractor, or representative.