Privacy Shield Statement
Last Updated: July, 2017
Metrics Delivered LLC, d/b/a NeverBounce, 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 data transferred to the United States from the European Union and Switzerland, respectively. With respect to EU and Swiss personal data, NeverBounce has certified that it adheres to the Privacy Shield Principles. If there is any conflict between this Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
To learn more about the Privacy Shield Program and view a list of participating organizations, please visit privacyshield.gov.
Information Management Practices
NeverBounce collects personal data from a variety of sources, including through our website (the “Site”). This personal data may include names, email addresses, phone numbers, postal addresses, payment information, and other details relevant to the service we provide (the “Service”). We may obtain personal data directly from visitors to our Site and clients who use our Service, or indirectly from business partners or other third parties. Clients may supply us with personal data about themselves as well as personal data about their customers and contacts as necessary to use the Service.
We limit our collection and use of personal data to that which is necessary to conduct our business, provide customer service, and comply with applicable law. We may disclose personal data to our vendors, business partners, and other third parties who assist us in providing the Service, or to third parties in the course of a business transaction such as a sale or transfer of our business or assets.
NeverBounce is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to any third party acting as an agent on its behalf. NeverBounce may be liable with respect to the onward transfer to third parties of EU and Swiss data subjects’ personal data received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.
Please note that in certain situations NeverBounce may be required to disclose personal data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
We are committed to the security of our clients’ personal data. Our operational and data processing systems are maintained in a secure environment, with appropriate administrative, technical, and physical safeguards to protect the personal data we maintain from unauthorized access.
Access and Limitation Rights
EU and Swiss data subjects have the right to access personal data maintained about them and to impose certain limits on the use and disclosure of such personal data. We will provide EU and Swiss data subjects with appropriate opportunities to opt out of our sharing their personal data as required by law, and will request opt-in consent prior to using EU or Swiss personal data for a purpose other than the purpose for which it was originally collected. With respect to personal data that our clients control and upload when they use our Service, we will refer data subjects to the relevant data controller to effect access and limitation requests.
If you wish to access your personal data or make a request regarding the use or disclosure of your personal data that we control, please contact us using the contact information below.
Questions, Complaints, Recourse, and Contact Information
EU-U.S. or Swiss-U.S. Privacy Shield Complaints
In accordance with the Privacy Shield Principles, NeverBounce is committed to resolving privacy concerns regarding our processing of personal data. EU and Swiss data subjects who have inquiries regarding this Privacy Shield Statement or our personal data practices should first contact the Administrator of Privacy by writing to email@example.com, by phone at 1-888-988-6694, or by postal mail sent to:
Attn: PRIVACY SHIELD INQUIRY
3690 Orange Place, Suite 310
Cleveland, OH 44122
NeverBounce has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles and the Swiss-U.S. Privacy Shield Principles to the BBB Dispute Resolution Process, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint filed with NeverBounce as described above, or if your complaint is not satisfactorily addressed by NeverBounce, please visit the www.bbb.org/EU-privacy- shield/for-eu- consumers/for more information, or to file a complaint.
If your complaint is not resolved through these channels, under limited circumstances you may have the ability to invoke binding arbitration.
NeverBounce is subject to the investigatory and enforcement authority of the Federal Trade Commission.