Introduction

Projector PSA 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 information transferred from the European Union and Switzerland to the United States, respectively. Projector PSA 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/.

Data Categories

We receive mostly business-related information from the EU and Switzerland, including contact information of individual representatives of the businesses with whom we are dealing, including, without limitation, names, addresses, work phone numbers, work email addresses, etc. of EU and Swiss Persons (“EU and Swiss Data”). In addition, our customers use our hosted technology platform to store and process EU and Swiss Data at their own discretion. Since EU and Swiss Data covered by this Notice is by definition sent to us by another company in the EU or Switzerland (i.e., a customer of Projector PSA, Inc.), the categories of data sent and the purposes of processing often depend on such other company, with whom the EU and Swiss Persons typically have a closer employment or business relationship (and which, therefore, can provide additional information on categories of data shared with us). EU and Swiss Persons may make a request directly to that EU or Swiss customer company of Projector PSA, Inc. to limit the collection or use of EU and Swiss Data, which is at the discretion of that EU or Swiss company depending on their business practices, and is not controlled by Projector PSA.

Purposes

We collect and use EU and Swiss Data for purposes of providing products and services to our customers, communicating with corporate business partners about business matters, processing EU and Swiss Data on behalf of corporate customers, providing information on our services, and conducting related tasks for legitimate business purposes. Your personal information will not be disclosed by us to a third party or used for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized.

Disclosure

We share EU and Swiss Data with our third-party service providers and contractors, who process EU and Swiss Data on behalf of Projector PSA, and are an important means by which Projector PSA provides its services. We also share EU and Swiss Data with other third parties for the purposes for which we receive the EU and Swiss Data (e.g., performance of contractual obligations and rights), and we may also disclose EU and Swiss Data where we are legally required to disclose (e.g., under statutes, contracts or otherwise) or the disclosure is permitted by law or the Privacy Shield Principles and we have a legitimate business interest in such disclosure. Projector PSA will take reasonable steps to ensure that these third-party service providers are obligated to protect personal Information on Projector PSA’s behalf.

With respect to marketing emails, EU and Swiss Persons may opt-out of receiving further email marketing communications from Projector PSA by contacting the Projector Administrator at the business that provided your EU or Swiss Data to us, or by following opt-out instructions that are contained in each marketing email.

Access and Review

If you are an EU or Swiss Person about whom we hold EU or Swiss Data, you have a right to request access to, and the opportunity to update, correct or delete, such EU or Swiss Data. To submit such requests or raise any other questions, please contact the business that provided your EU or Swiss Data to us. You can also contact us directly using the contact information below. We reserve the right to take appropriate steps to authenticate an applicant’s identity, and to assess potential impact to the privacy rights of other individuals or companies, in line with the Privacy Shield Principles.

Privacy Shield Contact

In compliance with the US-EU and Swiss-US Privacy Shield Principles, Projector PSA commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Projector PSA at:

  • Chief Privacy Officer
  • Projector PSA, Inc.
  • 85 Merrimac Street
  • Suite 200
  • Boston, Massachusetts 02114 USA
  • +1 617-431-4111
  • privacy@projectorpsa.com

Projector PSA has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Projector PSA may potentially be liable in cases of onward transfer to third parties. If a third-party providing services on our behalf processes your Personal Data in a manner that violates Privacy Shield Principles, the third-party is liable for damages unless it is proven that Projector PSA is responsible for the event giving rise to the violation. Projector PSA’s Privacy Shield compliance is under the jurisdiction of the US Federal Trade Commission.

Under certain limited conditions, for individuals may invoke binding arbitration before the Privacy Shield Panel of the U.S. Department of Commerce and the European Commission.

Additionally, Projector PSA may be required to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.