PURPOSE OF DATA COLLECTION
Privacy Shield Policy
Effective date: 24 July 2020
Update:A decision of the Court of Justice of the European Union on 16 July 2020 declared the EU-US Privacy Shield Framework (“Privacy Shield”) to be invalid as a mechanism for transferring personal data from the European Union to the United States. Following this decision, Ortto Inc. (“Ortto”, “we”, or “us”) continues to comply with the Privacy Shield as set out below.
Ortto relies on Standard Contractual Clauses (SCCs) for transfers of personal data from the European Union to the United States, which the Court of Justice of the European Union held to be a valid transfer mechanism, subject to the transferor determining that the level of protection afforded in the context of the transfer is essentially equivalent to the level of protection in the EU.
Ortto complies with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the transfer of personal data from the EU and Switzerland to the US. For purposes of this Privacy Shield Notice, “Personal Data” is information that identifies, directly or indirectly, a customer or consumer in the EU or Switzerland. Ortto has self-certified to the US Department of Commerce and declared its commitment to adhere to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability (the “Principles”). You can learn more about Privacy Shield at https://www.privacyshield.gov and see our Privacy Shield self-certification at https://www.privacyshield.gov/list. Ortto’s self-certification to the Privacy Shield is subject to the investigatory and enforcement authority of the Federal Trade Commission.
Personal Data We Process
Accessing Personal Data
The Privacy Shield Principles provide individuals located in the EU and Switzerland whose Personal Data we process the right to access their Personal Data and to review, correct, amend, or delete their Personal Data. Customers who would like to access their Personal Data may do so by logging into the Ortto user interface or emailing us at email@example.com. Consumers who would like to access their Personal Data should request access from the Ortto customer whose website they use.
Transfers to Third Parties and Your Choices
Contacting Us, Complaints and Dispute Resolution
In compliance with the Privacy Shield Principles, Ortto, Inc. commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Ortto, Inc. at:
1390 Market Street, Suite 200
San Francisco, CA 94102
Ortto, Inc. has further committed to refer unresolved Privacy Shield complaints to ICDR/AAA Privacy Shield Program, an alternative dispute resolution provider located in the United States. 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 ICDR/AAA Privacy Shield Program for more information or to file a complaint. The services of ICDR/AAA Privacy Shield Program are provided at no cost to you. If you are an EU or Swiss individual and unable to resolve any complaints through any of the above methods, you may be able to invoke binding arbitration through a Privacy Shield panel, in accordance with the Privacy Shield Framework at http://go.adr.org/privacyshieldfiling.html.