Last Updated: October 18, 2017
Artefact Product Group LLC (operating as10,000ft.) has subscribed to and will comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield (the “Frameworks”) as set forth by the U.S. Department of Commerce regarding the processing of Personal Information (as defined below) that is transferred from the European Economic Area (“EEA”) and Switzerland to the United States, respectively. 10,000ft. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles (the “Principles”). 10,000ft. created this Privacy Shield Notice to help you learn about how we handle Personal Information that is collected in the EEA and Switzerland and transferred to 10,000ft. in the U.S.
If there is any conflict between this Policy and the Principles, the Principles will govern. To learn more about the Frameworks please visit www.privacyshield.gov. You can view our certification at https://www.privacyshield.gov/list
This Privacy Shield Notice supplements our Privacy Notice above. Capitalized terms used in this Privacy Shield Notice have the meaning given to them by our Privacy Notice, unless specifically defined in this Notice. This Privacy Shield Notice applies to 10,000ft., which is subject to the investigatory and enforcement powers of the Federal Trade Commission.
How we Obtain Personal Information
We obtain and process Personal Information in different capacities.
- As a data controller, we collect and process EEA Personal Information directly from individuals, either via our publicly available websites, including www.10000ft.com, or in connection with our customer, partner, and vendor relationships.
- As a data processor, we process and host EEA Personal Information obtained from our customers when providing our services to our enterprise customers. In that context, we only process Personal Information on behalf and on the instructions of our customers, which are data controllers.
We commit to subject to the Principles all Personal Information received from the EEA and Switzerland in reliance on the Frameworks (which includes both types of activities).
Personal Information Received from the European Economic Area and Switzerland
We may receive from the EEA and Switzerland some or all of the information listed in our Privacy Notice. Some of that information may qualify as “personal information” or “personal data” (collectively, “Personal Information”) as defined in the Frameworks.
When we process Personal Information on behalf of our enterprise customers, they determine the categories of data they upload in our systems and the purposes of the processing. Accordingly, customers are responsible for providing notice to individuals.
Data Integrity and Purpose Limitation
We may use the Personal Information we receive from the EEA and Switzerland for the purposes set forth in our Privacy Notice or as you may otherwise be notified. We take reasonable steps to ensure that the Personal Information we process is relevant and reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the Personal Information. We will not process Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you. We will adhere to the Principles for as long as we retain the Personal Information collected under the Frameworks.
When we process Personal Information on behalf of our enterprise customers, we process and retain Personal Information as necessary to provide our services to our customers, or as required or permitted under applicable law.
Our Privacy Notice describes the types of third parties that we may disclose your Personal information to, and the purposes of such disclosures. If we disclose your Personal Information to a third party acting as a data controller or as an agent, we will comply with, and protect the Personal Information as provided in, the Accountability for Onward Transfer Principle. We remain responsible for the processing of Personal Information received under the Frameworks and subsequently transferred to a third party acting as an agent if the agent processes such Personal Information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.
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.
You may choose to change your Personal Information or cancel an account by contacting us using the contact details below. You can also unsubscribe from our marketing communications by following the instructions or unsubscribe mechanism in the e-mail message.
If we intend to use your Personal Information for a purpose that is materially different from the purposes listed in this policy or our Privacy Notice, or if we intend to disclose it to a third party acting as a controller not previously identified, we will offer you the opportunity to opt-out of such uses and/or disclosures where it involves non-sensitive information or opt-in where sensitive information is involved.
Recourse and Enforcement
We commit to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
If you have any questions or concerns, please write to us at the address listed below. If you are an EEA or Swiss resident, we will investigate and attempt to resolve reasonable complaints and disputes regarding our use and disclosure of Personal Information in accordance with the Principles. If an issue cannot be resolved via our internal dispute resolution mechanism, EEA and Swiss individuals may contact or submit a complaint, at no cost, to the Council of Better Business Bureaus, our US-based third party dispute resolution provider. To find out more, go to http://www.bbb.org/eu-privacy-shield/for-eu-consumers. For residual complaints not fully or partially resolved by other means, you may be able to invoke binding arbitration before the Privacy Shield Panel as detailed in the Principles.
If you have questions, concerns, or complaints about this Privacy Shield Notice or our privacy practices, please contact us.
Artefact Product Group LLC. (dba.10,000ft)
619 Western Ave. Suite 500
Seattle, WA 98104