Legal Disclaimer

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All the information on this website is published in good faith and for general information purpose only. We do not make any warranties about the completeness, reliability and accuracy of this information. Any action you take upon the information on our website is strictly at your own risk. We will not be liable for any losses and damages in connection with the use of our website.

From our website, you can visit other websites by following hyperlinks to these sites. While we strive to provide only links to useful and ethical websites, we have no control over the content and nature of these sites and the links to other websites do not imply a recommendation for all the content found on these sites.

Please be also aware that when you leave our website, other sites may have different privacy policies and terms which are beyond our control.

EU-U.S./Swiss-U.S. Privacy Shield

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Effective Date: Oct 22, 2018

Prosparency LLC (“Prosparency”) complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework, both 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. When processing EU and Swiss personal data, Prosparency has committed to apply the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability.

If there is a conflict between this Privacy Shield Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, you may visit https://www.privacyshield.gov.

Personal Data Processing Practices

Prosparency may obtain personal data from multiple sources, including from our clients. This personal data may include names, postal addresses, email addresses, employment information, and other details relevant to the Know your Subscriber (KYS™) services we provide. We may obtain personal data from our clients or our business partners. We use this information, as permitted by law, to qualify, verify and validate the personal data in order to facilitate the classification of the client’s subscribers according to the requested categories such as professional data user, non-professional data user or a probable that requires further investigation /analysis. The (KYS™) service/tool uses personal data of our clients’ subscribers, to help in the qualification and classification of the client’s subscribers, to ensure accurate reporting in order to reduce the audit liabilities for clients and to provide results which will facilitate communications with clients to respond to the qualification requests.

We do not disclose or transfer personal data to outside entities or third parties. However, we may share information to comply with law, protect our rights or the rights of third parties, for internal business purposes, or in connection with commercial transactions such as client’s request for audits on subscriber’s data usage, to ensure the maintenance of the Subscribers qualification status is accurate, in addition to the compliance obligation related to the clients reporting of subscriber’s data usage and for mergers or asset transfers.

Access and Limitation Rights

EU data subjects 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. As required by law, we would request opt-in consent prior to using EU or Swiss personal data for a purpose other than the purpose for which it was collected originally.

If you wish to make a request regarding access to your personal data or the use or disclosure of your personal data, please contact us using the contact information provided below.

Disclosures

Prosparency is responsible for the processing of personal data it receives under the Privacy Shield Frameworks. Prosparency complies with the Privacy Shield Principles for any onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

Please note that in certain situations Prosparency may be obligated to disclose personal data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Questions, Complaints, and Recourse

In compliance with the Privacy Shield Principles, Prosparency is committed to resolving privacy complaints regarding our handling of personal data. Data subjects with inquiries or complaints regarding this Privacy Notice should first contact Prosparency using the contact information listed below.

For complaints from data subjects that cannot be resolved directly with Prosparency, Prosparency will cooperate with either EU data protection authorities (DPAs) or the Swiss Federal Data Protection and Information Commissioner with respect to such unresolved complaints and will take appropriate steps to correct Privacy Shield compliance issues.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Prosparency is subject to the investigatory and enforcement authority of the Federal Trade Commission.

Contact Information

Data subjects may contact Prosparency regarding this Notice by emailing the site administrator or by postal mail sent to: