Buddy Media, Inc. (“Buddy Media”) respects your concerns about privacy. Buddy Media has certified that it abides by the Safe Harbor privacy principles as set forth 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. This Policy outlines our general policy and practices for implementing the Safe Harbor privacy principles for Consumer and Employee Personal Data. For purposes of this policy:
“Consumer” means any natural person who is located in the EEA or Switzerland, but excludes any individual acting in his or her capacity as an Employee.
“Customer” means any individual or entity that purchases or licenses Buddy Media’s products or services.
“Employee” means any current, former or prospective employee of Buddy Media or any of its European affiliates, who is located in the EEA or Switzerland.
“Personal Data” means any information that (i) is transferred to Buddy Media in the U.S. from the EEA or Switzerland, (ii) is recorded in any form, (iii) relates to an identified or identifiable Consumer or Employee, and (iv) can be linked to that individual.
Buddy Media’s Safe Harbor certification can be found at https://safeharbor.export.gov/list.aspx. For more information about the Safe Harbor principles, please visit http://www.export.gov/safeharbor. For more information about Buddy Media’s processing of Personal Data collected from Consumers on www.buddymedia.com, please visit Buddy Media’s Privacy Policy. For more information about Buddy Media’s processing of Personal Data about Employees, please see Buddy Media’s EEA Employee Data Privacy Notice, which is available from the company’s Human Resources Department.
How Buddy Media Obtains Personal Data
As a provider of software as a service (SaaS) solutions, Buddy Media obtains Consumer Personal Data in connection with its web-based platform. In addition, information about Consumers may be collected through automated technologies (such as cookies) used in connection with Buddy Media’s products or services. Buddy Media also collects Personal Data directly from Consumers. This collection occurs, for example, when a Consumer visits Buddy Media’s website and provides Personal Data to Buddy Media. In addition, Buddy Media obtains Consumer Personal Data, such as contact information, in connection with maintaining its Customer relationships and providing its products and services to Customers. Buddy Media obtains and processes Personal Data about its Employees when carrying out and supporting human resources functions and activities, including: (1) providing compensation and benefits; (2) administering payroll; (3) managing employee participation in human resources plans and programs; (4) carrying out obligations under employment contracts; (5) complying with applicable legal obligations, including government reporting and specific local law requirements; (6) managing employee performance; (7) recruiting and hiring job applicants; (8) conducting talent development; (9) managing the employee termination process; and (10) for other general human resources purposes. Buddy Media’s practices regarding the collection, storage, use, transfer, and other processing of Personal Data comply, as appropriate, with the Safe Harbor principles of notice, choice, onward transfer, access, security, data integrity, and enforcement and oversight.
Notice
Buddy Media provides information in its Privacy Policy regarding its Consumer Personal Data practices related to information collected on www.buddymedia.com, including the purposes for which Buddy Media collects and uses Consumer Personal Data it collects on its website. In circumstances in which Buddy Media acts as a service provider for its Customers, Buddy Media’s Customers are responsible for providing appropriate notice to their Consumers whose Personal Data are transferred to the U.S. Buddy Media notifies Employees about the purposes for which it collects and uses Employee Personal Data, the types of third parties to whom Buddy Media discloses the Personal Data, the choices Employees have for limiting the use and disclosure of their Personal Data, and how to contact Buddy Media about its practices concerning Personal Data. Information regarding Buddy Media’s Employee Personal Data practices is contained in Buddy Media’s EEA Employee Data Privacy Notice, which is available from the company’s Human Resources Department. Relevant information also may be found in privacy notices pertaining to specific processing activities.
Choice
In circumstances in which Buddy Media collects Personal Data directly from Consumers, it offers Consumers the opportunity to choose how Buddy Media communicates with Consumers and what Consumer Personal Data Buddy Media can collect. We do not use Personal Data for purposes incompatible with the purposes for which we originally collected the Personal Data without notifying the relevant individuals of such uses and offering an opportunity to opt out. Employees have the opportunity to make choices regarding certain Buddy Media Personal Data practices as provided in the EEA Employee Data Privacy Notice, which is available from the company’s Human Resources Department. Consumers may contact Buddy Media as indicated below regarding the company’s use or disclosure of their Personal Data. Employees may contact Buddy Media as indicated in the EEA Employee Data Privacy Notice. In circumstances in which Buddy Media maintains Personal Data about Consumers with whom Buddy Media does not have a direct relationship because Buddy Media obtained or maintains the Consumers’ data as a service provider for its Customers, Buddy Media’s Customers are responsible for providing the relevant individuals with certain choices with respect to the Customers' use or disclosure of the individual’s Personal Data. Buddy Media may disclose Personal Data without offering an opportunity to opt out (i) to service providers we have retained to perform services on our behalf, (ii) if it is required to do so by law or legal process, (iii) to law enforcement or other government authorities, or (iv) when Buddy Media believes disclosure is necessary to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity. Buddy Media also reserves the right to transfer Personal Data in the event it sells or transfers all or a portion of its business or assets. Should such a sale or transfer occur, Buddy Media will use reasonable efforts to direct the transferee to use the Personal Data in a manner that is consistent with Buddy Media’s privacy policies.
Onward Transfer of Personal Data
Buddy Media may share Consumer Personal Data collected on www.buddymedia.com with the types of third parties identified in the “Sharing of Information” section of Buddy Media’s Privacy Policy. The EEA Employee Data Privacy Notice, which is available from the company’s Human Resources Department, describes the sharing of Employee Personal Data. Buddy Media requires third parties to whom it discloses Personal Data and who are not subject to the European Union Data Protection Directive 95/46 or an adequacy finding to either (i) subscribe to the relevant Safe Harbor principles or (ii) contractually agree to provide at least the same level of protection for Personal Data as is required by the relevant Safe Harbor principles.
Access
Where appropriate, Buddy Media provides Consumers and Employees with reasonable access to the Personal Data Buddy Media maintains about them. Buddy Media also provides a reasonable opportunity for Consumers and Employees to correct, amend or delete that information where it is inaccurate, as appropriate. Buddy Media 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. The right to access personal information also may be limited in some circumstances by local law requirements. Consumers may request access to their Personal Data by contacting Buddy Media as indicated below. Employees may request to access their Personal Data by contacting Buddy Media as indicated in the EEA Employee Data Privacy Notice. In circumstances in which Buddy Media maintains Personal Data about Consumers with whom Buddy Media does not have a direct relationship because Buddy Media obtained or maintains the Consumers’ data as a service provider for its Customers, Buddy Media’s Customers are responsible for providing Consumers with access to the Personal Data and the right to correct, amend or delete the information where it is inaccurate. In these circumstances, Consumers should direct their questions to the appropriate Buddy Media Customer. When a Consumer is unable to contact the appropriate Customer, or does not obtain a response from the Customer, Buddy Media will provide reasonable assistance in forwarding the individual’s request to the Customer.
Security
Buddy Media takes reasonable precautions to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Data Integrity
Buddy Media takes reasonable steps to ensure that the Personal Data the company processes are (i) relevant for the purposes for which they are to be used, (ii) reliable for their intended use, and (iii) accurate, complete and current. In this regard, Buddy Media depends on its Consumers, Customers and Employees 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. Consumers may contact Buddy Media as indicated below to request that Buddy Media update or correct their Personal Data. Employees may contact Buddy Media as indicated in the EEA Employee Data Privacy Notice to request that Buddy Media update or correct their Personal Data.
Enforcement and Oversight
Buddy Media has established procedures for periodically verifying implementation of and compliance with the Safe Harbor principles. Buddy Media 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 Buddy Media’s processing of their Personal Data with Buddy Media’s Information Security Team, whose contact information is below. Employees may file a complaint concerning Buddy Media’s processing of their Personal Data with the company’s Human Resources Department. Buddy Media will take steps to remedy any issues arising out of a failure to comply with the Safe Harbor principles. Please contact Buddy Media as specified below to address any complaints regarding the company’s Personal Data practices.
If a Consumer complaint cannot be resolved through Buddy Media's internal processes, Buddy Media will cooperate with JAMS pursuant to the JAMS International Mediation Rules, which are accessible on the JAMS website at www.jamsadr.com/international-mediation-rules.
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. Buddy Media will assume the costs of the administrative fees if the mediator makes a written recommendation that finds Buddy Media 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 Buddy Media. In circumstances in which Buddy Media maintains Personal Data about Consumers with whom Buddy Media does not have a direct relationship because Buddy Media obtained or maintains the Consumers’ data as a service provider for its Customers, Consumers may submit complaints concerning the processing of their Personal Data to the relevant Customer, in accordance with the Customer’s dispute resolution process. Buddy Media will participate in this process at the request of the Customer or the Consumer. If the issue cannot be resolved through the Customer’s internal dispute resolution mechanism, the Consumer may submit the complaint to the relevant data protection authority in the EEA or Switzerland. If an Employee complaint cannot be resolved through Buddy Media’s internal processes, Buddy Media will cooperate with the relevant EEA or Swiss data protection authorities, as appropriate.
How to Contact Buddy Media
To contact Buddy Media about questions or concerns about this Safe Harbor Privacy Policy or Buddy Media’s practices concerning Personal Data:
Write to:
Buddy Media UK, Ltd.
Attn: Information Security Team
8 Duncannon Street Suite 304b
Strand – London
WC2n 4JF
Email: privacy@buddymedia.com