Poll Everywhere and the EU-U.S. Privacy Shield

Updated September 22, 2016

Poll Everywhere complies with the EU-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 to the United States. Poll Everywhere 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 www.privacyshield.gov.

Types of EU Personal Data Collected. Poll Everywhere’s participation in the Privacy Shield applies to all personal data that is subject to the Poll Everywhere Privacy Statement and is received from the European Union and European Economic Area (“EU Personal Data”). Poll Everywhere will comply with the Privacy Shield Principles in respect of EU Personal Data.

Purposes of EU Personal Data Collection and Use. Poll Everywhere will only process EU Personal Data in ways that are compatible with the purpose for which Poll Everywhere collected the EU Personal Data, or for purposes that the individual or entity providing the EU Personal Data later authorizes. Before we use your EU Personal Data for a purpose that is materially different than the purpose for which it was collected or that you later authorized, we will provide you with the opportunity to opt out. Poll Everywhere maintains reasonable procedures to help ensure that EU Personal Data is reliable for its intended use, accurate, complete, and current.

Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your EU Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security. Poll Everywhere maintains reasonable and appropriate security measures to protect EU Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

Access Rights. You may have the right to access the EU Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EU Personal Data, you can submit a written request to us as provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

Data Transfers to Third Parties. Poll Everywhere’s accountability for EU Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Poll Everywhere remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process EU Personal Data on its behalf do so in a manner inconsistent with the Principles, unless Poll Everywhere proves that it is not responsible for the event giving rise to the damage.

Questions or Complaints. As further explained in the "How to Contact Us" section of the Poll Everywhere Privacy Policy, we encourage you to contact us should you have a Privacy Shield-related (or general privacy-related) question or complaint. For any complaints that cannot be resolved with Poll Everywhere directly, Poll Everywhere has chosen to utilize the JAMS Privacy Shield Program as an independent recourse mechanism available to investigate unresolved complaints (as further described in the Privacy Shield Principles). Please visit https://www.jamsadr.com/eu-us-privacy-shield for relevant JAMS contacts. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. Poll Everywhere is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).