Privacy Policy

ADDENDUM 1

EU-U.S. Privacy Shield Framework

Effective as of September 30, 2016

We comply with the EU-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 EU to the United States. To learn more about the Privacy Shield program, and to view our certification, please visit http://www.privacyshield.gov.

Our participation in the Privacy Shield applies to all personal information that is subject to the Privacy Policy and is received from the European Union, European Economic Area, and Switzerland. We will comply with the Privacy Shield Principles in respect of such personal information. We also maintain an affirmative commitment to the U.S.-Swiss Safe Harbor Framework and its principles, which will not be affected by Our participation in the Privacy Shield.

EU individuals have rights to access personal information about them and to limit use and disclosure of their personal information. We have committed to respect those rights. If You wish to limit the use or disclosure of Your personal information, please contact Us in the manner described under “Questions/Changes in Policy” set forth in the Privacy Policy.

Our accountability for personal information that We receive under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, We remain responsible and liable under the Privacy Shield Principles if third-party agents that We engage to process the personal information on Our behalf do so in a manner inconsistent with the Principles, unless We prove that We are not responsible for the event giving rise to the damage.

As further explained in under “Questions/Changes in Policy” set forth in the Privacy Policy, we encourage you to contact us should you have a Privacy Shield-related (or general privacy-related) complaint. We will respond within 45 days. If we fail to respond within that time, or if our response does not address your concern, you my contact the International Centre for Dispute Resolution, the International division of the American Arbitration Association. Please visit http://info.adr.org/safeharbor/ for additional information and to file a complaint.

For any complaints that cannot be resolved with Us directly, We have chosen to cooperate with EU data protection authorities (DPAs) and comply with the information and advice provided to it by an informal panel of DPAs in relation to such unresolved complaints (as further described in the Privacy Shield Principles). Please contact us to be directed to the relevant DPA contacts. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.

We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

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