LAST UPDATED: February 25, 2019
SOVA Systems (“SOVA”, “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”). SOVA 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”) and Switzerland.
This
Privacy Shield Policy (“Privacy Shield Policy”)
, the
Services Privacy Policy (“Services Privacy Policy”) and the
Website Privacy Policy (“Website Privacy Policy”) describe the privacy practices that we implement for Personal Data received from the EEA 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 as concerns the Personal Data received under the Privacy Shield, 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 .
We do not have a direct relationship with Users. Information collected from Users on Customers’ web portals or on the SOVA mobile app is subject to our Customers’ privacy policies. Users who have questions or concerns about information collected when they access their company web portal via SOVA Services, or about content found there, should contact our Customer through the web portal or app on which the data is available. Users who are uncertain about whom to contact may contact us at
privacy@sovasystems.com . User questions will be directed to the appropriate Customer.
Contents of this Privacy Shield Policy
Privacy Shield Principles
1. and 2. 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.
If you are a Customer, SOVA may act as an agent for you in relation to the Personal Data that you provide or make available to SOVA. SOVA usually will not have a relationship with your Users. Here, the Customer is responsible for ensuring that Users are provided with appropriate notice and choice with respect to their Personal Data. In its role as a processor and as required by applicable law, SOVA generally offers individuals in the EU and Switzerland (together: “EEA/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/CH Consumer. To the extent required by the Privacy Shield Principles, SOVA obtains opt-in consent for certain uses and disclosures of sensitive data. EEA/CH Consumers may contact SOVA as indicated below regarding the SOVA’s use or disclosure of their Personal Data. Unless SOVA offers EEA/CH Consumers an appropriate choice, SOVA uses Personal Data only for purposes that are materially the same as those indicated in this Policy.
3. Data Integrity and Purpose Limitation
We only collect Personal Data that is relevant to providing our Services. In
general, the personal information we collect enables us to provide
goods and services to customers and users and helps
us to personalize and improve the experience at our web sites. We use
the information for different purposes depending upon the goods or
services being provided. Among other things, these purposes may include
the following: handling orders; delivering products and services;
processing payments; processing for other purposes as required by our
services; communicating with customers and users about orders, products, services and promotional offers; updating our
records and generally maintaining customer, user, vendor, and seller
accounts; displaying content; and recommending merchandise and services
that might be of interest to our customers, users, vendors, or sellers.
We also use this information to prevent or detect fraud or abuses of our
web sites, and enable third parties to carry out technical, logistical
or other functions on our behalf.
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 SOVA’s Services, accurate, complete, and current.
4. Accountability for Onward Transfers
This Policy, the Services Privacy Policy and the Website Privacy Policy describe how SOVA shares Personal Data.
Except as permitted or required by applicable law and in accordance with SOVA’s role as a controller or processor, SOVA provides EEA/CH Consumers with an opportunity to opt out of sharing their Personal Data with third-party controllers. SOVA requires third-party controllers to whom it discloses the Personal Data of EEA/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/CH Consumer, (b) provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and (c) notify SOVA 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.
SOVA may disclose Personal Data to trusted third parties as indicated in the Services Privacy Policy and the Website Privacy Policy without offering an opportunity to opt out.
SOVA 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.
5. 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.
6. Access to Personal Data
Our Services Privacy Policy and Website 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@sovasystems.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 SOVA acts on behalf of its Customers, SOVA will assist Customers in responding to Users exercising their rights under the Privacy Shield Principles.
If you are a User of a Customer, please contact the Customer directly with your request to access or limit the use or disclosure of your Personal Data. If you contact us with the name of the Customer to which you provided your Personal Data, we will refer your request to that Customer and support them in responding to your access request.
7. Recourse, Enforcement and Dispute Resolution
If you have any questions or concerns, please write to us at the address listed below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with the Privacy Shield Principles.
In the event we are unable to resolve your concern, you may contact
JAMS , which provides an independent third-party dispute resolution body based in the United States, and they will investigate and assist you free of charge. A binding arbitration option may also be available to you in order to address residual complaints not resolved by any other means. SOVA is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”).
Your Privacy Shield and Data Protection Contact for the Personal Data that we Process in connection with SOVA Services is:
Attn: General Counsel, Legal Dept.
SOVA Systems
PO Box 600063
San Diego, CA 92160
Phone: +1 619 892 6561
Please include sufficient information so we can understand and respond to your specific question.
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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 Services Privacy Policy and Website Privacy Policy. You can determine when this Privacy Shield Policy was last revised by referring to the date at the top of this page.
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If you have any questions regarding this Privacy Shield Policy, please contact us by email at privacy@sovasystems.com , or call +1 619 892 6561, or write to:
Attn: Privacy Team
SOVA Systems
PO Box 600063
San Diego, CA 92160
Please be sure to include sufficient information so we can understand and respond to your specific question or request.
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