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Privacy Shield Notice

EFFECTIVE DATE: December 21, 2018

Affirmative Commitment to the Privacy Shield Framework

Primal Cause, Inc. complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, the “Frameworks”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Economic Area (“EEA”) and Switzerland to the United States. Primal Cause, Inc. 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/

In compliance with the Privacy Shield Principles, Primal Cause, Inc. commits to resolve complaints about our collection or use of your personal information. EEA and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact our general mailbox at: [email protected]

Primal Cause, Inc. has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EEA and Switzerland in the context of the employment relationship.

Personal Information

Any information that you provide to us, such as your name, e-mail address, mailing address and telephone number is held in strict confidence. When you provide personal information to us, such personal information will be used in order to provide you with access to the Sites or our other products, services and/or information. We may also use the personal information to help us understand who is using our products and services and help us manage business development activities. Except as set out in this privacy policy, we will not disclose or sell your personal information to any third parties.

Third parties who may process personal data

We use a limited number of third party service providers and partners to assist us in providing our products and services to our clients. We maintain contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our Privacy Shield obligations.

We may share personal data with the providers of our business productivity software such as consumer relationship management software, marketing and data enhancement software (including marketing communications automation platforms), customer success software, and billing and collections software in order to enable their respective business functions. These service providers may access, process, or store personal data in the course of providing their services.

Where we have received your personal data under the Frameworks and subsequently transfer it to a third party agent or service provider for processing, then we remain liable if such third party agent or service provider processes your personal data in a manner inconsistent with the Frameworks’ principles.  We may also disclose your personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

For clarity, we do not share any personal data of EEA and Swiss individuals that may be collected with our SaaS platform in GridBuddy or AppBuddy Cloud.

Your right to access, limit use, and limit disclosure

EEA and Swiss individuals have rights to access personal data about them, and to limit use and disclosure of their personal data. With our Privacy Shield self-certification, we have committed to respecting those rights. If you wish to request access, to limit use, or to limit disclosure, please contact [email protected].

E-Mail Privacy

We may use subscription forms at various times to request information by subscribing to online communications and/or email alerts based on subscriber preference. We provide confirm opt-in opportunities for any email list(s) that you choose to receive. We use your email address to confirm your subscription and the validity of the address provided. You can unsubscribe or opt/out for any or all email lists or newsletters you may receive. Emails sent to you include the information necessary to unsubscribe.

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Sites.

Links to other websites

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Security Management and Data Security

 We take great care to ensure that your personal information is securely stored. We restrict access of personal data to our authorized personnel, employees, contractors and agents who need to know that information in order to operate, innovate, and deliver our services.

Personal information will only be disclosed to our partners for the purpose of administering our programs. These partners will operate under this privacy policy in protecting your personal information.

While we take reasonable precautions against possible security breaches of the Sites and our customer databases and records, no website or Internet transmission is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal information safe (including your account password), and to log out of your account after use.

Notification of Changes

From time to time, we will occasionally update our Privacy Policy and post or link the updated Privacy Policy to the Sites. If there are any material changes to how we use your personal information, we will notify via email and provide you the opportunity to opt-out prior to any substantial change that has been taken. However, if you have opted out of all communication from us you will not be contacted, nor will your personal information be used in this new manner. We encourage you to periodically review our privacy policy to be informed of how we are committed to protecting your privacy.

Legal Disclaimer

Though we make every effort to preserve your privacy, we may need to disclose personal information when required by law or in the good-faith belief that such action is necessary in order to conform to the edicts of the law, comply with a legal process or to establish or exercise our legal rights or defend against legal claims.

Inquiries and complaints 

If you have any questions regarding this notice or if you need to update, change or remove personal data that we control, you can do so by contacting [email protected] or calling 1-877-648-5427, or by regular mail addressed to:

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, Primal Cause, Inc. will cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC). Primal Cause, Inc. will comply with information and advice provided by the DPAs with respect to such unresolved concerns, and will take appropriate steps to correct Privacy Shield compliance issues.

Under certain conditions, more fully described on the Privacy Shield website at www.privacyshield.gov, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Investigatory and enforcement powers of the FTC

Primal Cause, Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).