Privacy Policy – Privacy Shield

This policy is effective as of 6/30/2020

Scope of this Notice

This Notice applies to data processed by AppSuite in conjunction with operating our CRM products. This Notice does not apply to AppSuite’s employee data, or the data that we receive directly through AppSuite’s publicly accessible websites.

Privacy Shield Compliance

AppSuite complies with the EU-U.S. Privacy Shield Framework and 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, United Kingdom and/or Switzerland, as applicable, to the United States.  AppSuite 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 processed (categories of data)

AppSuite sells customer relationship management (CRM) solutions that our customers use to operate their businesses and manage their customer relationships. In providing these tools, AppSuite processes data that our customer’s customers enter in to our products or instruct us to process on their behalf. AppSuite’s customers decide what data is collected. Typically the information includes personal and non-personal information about our customers’ customers (e.g. names, addresses, phone numbers, e-mail addresses, birthdates, location, device information, debugging data etc.).  AppSuite’s customers also provide us with the purchasing activity of their customers, which we store and make available for our customer’s internal use.

Purposes

AppSuite processes Customer Data pursuant to our subscription agreement. Customers may also engage us for professional services and customer support. To fulfill our contractual obligations, AppSuite may access Customer Data to provide services, to correct and address technical or service problems, or to follow instructions of the customer who submitted the data, or in response to contractual requirements.

Third Parties who may receive personal data (Onward Transfer)

AppSuite may engage a limited number of third-party service providers to assist us in providing our services to customers. These third-party providers may offer customer support services, data storage services (data centers), or technical operations. These third parties may access, process, or store personal data in the course of providing their services.

AppSuite maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our Privacy Shield obligations. AppSuite may be liable if the third parties fail to meet their obligations.

A list of the third-party processors engaged by AppSuite can be found here

Compelled disclosure

AppSuite may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Data Integrity & Security

AppSuite employs procedural and technological measures that are reasonably designed to help protect personal information from loss, unauthorized access, disclosure, alteration, or destruction. For example, among other measures, we ensure our data processing facilities meet strict industry best practice certifications and we have established technical safeguards such as encryption, firewalls and security patches.

Data access and correction, your choices for limiting use and disclosure

If you are an individual based in the EU, the United Kingdom or in Switzerland and our product holds your personal data, you may request access to your personal data. You also have the right to update, correct or delete your personal data. Also, the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework requires that participants offer data subjects a choice to opt out of uses and disclosures of their data that are materially different from the purposes for which that data was originally collected or subsequently authorized. AppSuite is committed to respect your rights.

AppSuite personnel have limited ability to access data submitted by its customers to the AppSuite Product(s) and does not have any personal relationship with the individuals whose personal data it processes on behalf of its customers. If you wish to request access to, correct or delete, or to limit the use or disclosure of your personnel data please provide us the name of the AppSuite customer who has submitted your data into the AppSuite Product(s). We will refer your request to that customer and will support our customer as needed in responding to your request.

Inquiries and complaints

We encourage you to direct any inquiries or complaints concerning our Privacy Shield compliance to AppSuite Inc, attn. Privacy Office, 1231 Gleneagles Ct. Lake Geneva, WI 53147-4913, USA, or call us at (561)208-6406 ext 101, or email us at [email protected] We will investigate and attempt to resolve complaints and disputes in a manner that complies with the principles described in this Notice. If you have a comment or concern that cannot be resolved with us directly within forty-five (45) days time, or if our response does not address your concern, you may contact JAMS, an independent third party dispute resolution body based in the Unites States. JAMS has committed to respond to complaints and to provide appropriate dispute resolution at no cost to you. To contact JAMS and/or learn more about the company’s dispute resolution services, including instructions for submitting a complaint, please visit: https://www.jamsadr.com/eu-us-privacy-shield. If neither AppSuite nor JAMS resolves your complaint, you may pursue binding arbitration through the Privacy Shield Panel.

U.S. Federal Trade Commission enforcement

AppSuite’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.