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Privacy Shield Notice

Last Updated: May 14, 2018

Effective Date: May 14, 2018

Introduction

Curalate, Inc. (“Curalate”) complies with the EU-U.S. Privacy Shield Framework and the 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. Curalate 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 https://www.privacyshield.gov. A current list of organizations certified under the EU-U.S. Privacy Shield framework (“Privacy Shield List”) is available at https://www.privacyshield.gov/list.

What personal data do we collect?
Curalate provides online tools services that allow our clients to engage with their customers via social media and other online channels. These include tools for analytics, social engagement, and user-generated content (UGC) curation. In order to provide these tools, Curalate must occasionally collect, process, and store personal data on behalf of our clients. This data may include public social media content (including images, videos, and text) and email addresses.

Why do we process personal data?
Curalate processes personal data for the purpose of providing our tools and services to our clients. This includes helping our clients measure the performance of their digital marketing efforts on social media and other online channels.

Inquiries or Complaints
First, if you have any questions about our handling of your personal data under Privacy Shield, or about our privacy practices generally, please contact us at privacy@curalate.com or Curalate, Inc., Attn: Data Protection Officer, 1628 John F Kennedy Blvd, Suite 1400, Philadelphia, PA 19103. We will respond to your inquiry as soon as possible and within 30 days.

Second, if you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Finally, if your concern continues to be unresolved, you may pursue binding arbitration through the Privacy Shield Arbitration Panel. To learn more about the Privacy Shield Panel, click here.

Third Parties
We may occasionally rely on third parties, including cloud computing providers, to perform services on our behalf. If we transfer personal information received under the Privacy Shield to a third party, the third party’s access, use, and disclosure of the personal data must also be in compliance with our Privacy Shield obligations, and we will remain liable under the Privacy Shield for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage.

Your rights to access, to limit use of, and to limit disclosure of personal data.
EU individuals and Swiss individuals have the right to access personal data about them, and to limit the use and the disclosure of their personal data. With our Privacy Shield certification, Curalate has committed to respect those rights. If you wish to request access to your personal data, to limit use of your personal data, or to limit disclosure of your personal data, please contact us at privacy@curalate.com. Given that Curalate only collects personal data on behalf of its clients, please provide the name of the client in question (or, alternatively, the website in question) when contacting Curalate. We will work with the client in question to respond to your request in a timely manner.

U.S. Federal Trade Commission Enforcement
Curalate is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) or any other U.S. authorized statutory body.

Lawful Requests
We may be required to disclose personal information that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Contact Us
You may direct any questions or complaints concerning our Privacy Shield compliance to privacy@curalate.com or at our mailing address below. We’ll happily work with you to address your inquiry in a timely manner.

Curalate, Inc.
Attn: Data Protection Officer
1628 John F Kennedy Blvd
Suite 1400
Philadelphia, PA 19103