Poll Everywhere, Inc. (“Poll Everywhere”) has certified that the company abides by the Safe Harbor privacy principles as set forth in the U.S.-EU & U.S.-Swiss Safe Harbor Frameworks by the U.S. Department of Commerce regarding the collection, storage, use, transfer and other processing of Personal Data transferred from the European Economic Area (“EEA”) or Switzerland to the United States.
“Personal Data” means any information that (i) is transferred from the EEA or Switzerland to Poll Everywhere in the U.S. and (ii) relates to an identified or identifiable Consumer.
As a provider of polling services, Poll Everywhere obtains Personal Data directly from Consumers who use Poll Everywhere products or services, as well as from business customers (such as conference companies and employers) who purchase Poll Everywhere products and services for use by their employees and other individuals. Poll Everywhere requires its business customers to comply with applicable laws governing the collection, use and other processing of Personal Data.
In all cases, as described below, Poll Everywhere’s practices regarding the collection, storage, use, transfer, and other processing of Personal Data comply with the Safe Harbor principles of notice, choice, onward transfer, access, security, data integrity, and enforcement and oversight.
In circumstances in which Poll Everywhere collects Personal Data directly from Consumers, we offer Consumers the opportunity to choose whether Poll Everywhere may (i) disclose their Personal Data to certain third parties for those parties’ own purposes, or (ii) use their Personal Data for a purpose that is incompatible with the purpose for which the information was originally collected or which was subsequently authorized by the individual.
We may use the information we have about Consumers to offer them products and services that we believe may be of interest to them. We may offer these products and services in conjunction with our business and marketing partners. Consumers may direct us not to use or share their information for these purposes by emailing firstname.lastname@example.org.
Where Poll Everywhere receives Personal Data from its business customers, we have informed the business customers that they are responsible for providing the relevant individuals with a choice regarding the business customer’s use and disclosure of Personal Data.
Poll Everywhere may share Personal Data with service providers that we have retained to perform services on the Poll Everywhere’s behalf. Poll Everywhere requires service providers to whom it discloses Personal Data and who are not subject to laws based on the European Union Data Protection Directive 95/46/EC to either (i) subscribe to the Safe Harbor principles or (ii) contractually agree to provide the level of protection for Personal Data as is required by the relevant Safe Harbor principles.
Where appropriate, Poll Everywhere provides Consumers with reasonable access to the Personal Data that Poll Everywhere maintains about them. Poll Everywhere also provides a reasonable opportunity for Consumers to correct, amend or delete that information where it is inaccurate. We may limit or deny access to Personal Data where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Safe Harbor principles. Users who have established an account with Poll Everywhere may access their Personal Data using their accounts. Visitors may request access to their Personal Data by contacting Poll Everywhere at email@example.com.
In circumstances in which Poll Everywhere receives Personal Data from business customers, we have informed our business customers that they are responsible for providing Consumers with access to the Personal Data and a reasonable opportunity to correct, amend or delete the information where it is inaccurate. Consumers who use Poll Everywhere services through our business customers should direct their access and correction requests to the relevant business customer (e.g., employer or conference company).
Poll Everywhere takes precautions to help protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Poll Everywhere takes reasonable steps to ensure that the Personal Data the company processes is (i) relevant for the purposes for which it is to be used, (ii) reliable for its intended use, and (iii) accurate, complete and current.
Poll Everywhere depends on Consumers and business customers to update and correct Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized by the individuals. Users who have established an account with Poll Everywhere may update their Personal Data using the account. Visitors may update their Personal Data by contacting Poll Everywhere at firstname.lastname@example.org. In addition, Poll Everywhere has informed its business customers that they are responsible for taking reasonable steps to ensure that the Personal Data they provide to Poll Everywhere is reliable for its intended use and is accurate, complete and current.
Poll Everywhere has established procedures for periodically verifying implementation of and compliance with the Safe Harbor principles. Poll Everywhere conducts an annual self-assessment of its Personal Data practices to verify that the attestations and assertions the company makes about its privacy practices are true and that the company’s privacy practices have been implemented as represented.
Consumers may file a complaint concerning Poll Everywhere’s processing of their Personal Data by emailing email@example.com. If the complaint cannot be resolved through Poll Everywhere’s internal processes, we will cooperate with JAMS pursuant to the JAMS International Mediation Rules, which are accessible on the JAMS website at http://www.jamsadr.com/rules-international-rules. Poll Everywhere will take steps to remedy any issues arising out of a failure to comply with the Safe Harbor principles.
In circumstances in which Poll Everywhere receives Personal Data from a business customer, Consumers may submit complaints concerning the processing of their Personal Data to the relevant business customer, in accordance with that customer’s dispute resolution process.
JAMS mediation may be commenced as provided for in the JAMS International Mediation Rules. The mediator may propose any appropriate remedy, such as publicity for findings of non-compliance, payment of compensation for losses incurred as a result of non-compliance, or cessation of processing of the Personal Data of the Consumer who has brought the complaint. Poll Everywhere will assume the costs of the administrative fees if the mediator makes a written recommendation that finds Poll Everywhere in breach of its duties pursuant to the Safe Harbor. The mediator or the Consumer also may refer the matter to the U.S. Federal Trade Commission, which has Safe Harbor enforcement jurisdiction over Poll Everywhere.
To contact Poll Everywhere with questions or concerns about this Safe Harbor Privacy Notice or Poll Everywhere’s practices concerning Consumer Personal Data, please email firstname.lastname@example.org or write to:
Poll Everywhere, Inc. Attn: Legal Department 1550 Bryant St. Suite 500 San Francisco, CA 94103
PLEASE DO NOT SEND ANY SENSITIVE INFORMATION TO US VIA UNENCRYPTED EMAIL. Also, please note that we will need to verify and authenticate any emailed requests for access or changes to your Personal Data or account information.