EU-U.S. and Swiss-U.S. Privacy Shield Policy
Current version: 27 April 2020
The previous Privacy Shield Policy can be found here.
Ziflow Inc.(“Ziflow”, “we”, “our” or “us”) has subscribed to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield”). Ziflow adheres to the Privacy Shield Principles including the Supplemental Principles, (collectively, the “Privacy Shield Principles”) for Personal Data received from entities in the European Economic Area (the “EEA”), the United Kingdom (“UK”) and Switzerland.
If there is any conflict between the terms in this Privacy Shield Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern to the extent of the conflict. To learn more about the Privacy Shield program visit www.privacyshield.gov, and to view our certification, please visit https://www.privacyshield.gov/list.
Privacy Shield Principles
Notice and Choice
Ziflow may act as an agent for you in relation to the Personal Data that you provide or make available to Ziflow. In its role as a controller and as required by applicable law, Ziflow generally offers individuals in the EU, UK and Switzerland (together: “EEA/UK/CH Consumers”) the opportunity to choose whether their Personal Data may be (i) disclosed to third-party controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant EEA/UK/CH Consumer. To the extent required by the Privacy Shield Principles, Ziflow obtains opt-in consent for certain uses and disclosures of sensitive data. EEA/UK/CH Consumers may contact Ziflow as indicated below regarding the Ziflow’s use or disclosure of their Personal Data. Unless Ziflow offers EEA/UK/CH Consumers an appropriate choice, Ziflow uses Personal Data only for purposes that are materially the same as those indicated in this Policy.
Data Integrity and Purpose Limitation
We only collect Personal Data that is relevant to providing our Services. We process Personal Data compatible with us providing the Services or as otherwise notified to you. We take reasonable steps to ensure that the Personal Data received under the Privacy Shield is needed for Ziflow’s Services, accurate, complete, and current.
Accountability for Onward Transfers
Except as permitted or required by applicable law and in accordance with Ziflow’s role as a controller or processor, Ziflow provides EEA/UK/CH Consumers with an opportunity to opt out of sharing their Personal Data with third-party controllers. Ziflow requires third-party controllers to whom it discloses the Personal Data of EEA/UK/CH Consumers to contractually agree to (a) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant EEA/UK/CH Consumer, (b) provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and (c) notify Ziflow and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Privacy Shield Principles.
We may also need to disclose Personal Data in response to lawful requests by public authorities, for law enforcement or national security reasons, or when such action is necessary to comply with a judicial proceeding or court order, or when otherwise required by law. We do not offer an opportunity to opt out from this category of disclosure.
We use reasonable and appropriate physical, electronic, and administrative safeguards to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data and the risks involved in processing that information.
Access to Personal Data
When Ziflow acts on behalf of its Users, Ziflow will assist Users in responding to individuals exercising their rights under the Privacy Shield Principles.
Privacy Shield Recourse and Enforcement
In compliance with the Privacy Shield Principles, Ziflow 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 Ziflow Inc. at:
firstname.lastname@example.org or by filling out the form on our Contact page.
Ziflow 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 data transferred from the EU and Switzerland.
Under certain conditions, more fully described on the Privacy Shield Principals website https://www.privacyshield.gov, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Ziflow is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”).
Changes to this Privacy Shield Policy