EU-U.S. and Swiss-U.S. Privacy Shield Policy
Superseded on 27 Apr 2020.
This page has been updated. Please see our current Privacy Shield Policy 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.
This Ziflow Privacy Shield Policy (“Privacy Shield Policy”) and the Ziflow Privacy Policy (“Privacy Policy”) describe the privacy practices that we implement for Personal Data received from the EEA, UK or Switzerland in reliance on the Privacy Shield. This Privacy Shield Policy uses terms which are defined in the Privacy Policy.
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
Our Privacy Policy describes how we use Personal Data we receive from different sources. This Privacy Shield Policy describes how we process Personal Data covered by the Privacy Shield.
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
This Policy and the Privacy Policy describe how Ziflow shares Personal Data.
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.
Ziflow may disclose Personal Data to trusted third parties as indicated in the Privacy Policy without offering an opportunity to opt out. Ziflow requires that its agents and service providers that have access to Personal Data within the scope of this Privacy Shield Policy provide the same level of protection as required by the Privacy Shield Principles. We ensure that our agents process Personal Data received under the Privacy Shield in a manner consistent with our obligations under the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
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.
Data Security
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
Our Privacy Policy explains how you may access and/or submit requests to review, correct, update, suppress, or delete Personal Data. You can ask to review and correct Personal Data that we maintain about you by sending a written request to privacy@ziflow.com. We may limit or deny access to Personal Data where providing such access is unreasonably burdensome, expensive under the circumstances, or as otherwise permitted by the Privacy Shield Principles.
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:
privacy@ziflow.com 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.
Ziflow is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”).
Changes to this Privacy Shield Policy
This Privacy Shield Policy may be changed from time to time, consistent with the requirements of the Privacy Shield and in accordance with the process described in the Privacy Policy. You can determine when this Privacy Shield Policy was last revised by referring to the “CURRENT VERSION” date at the top of this page.
