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This Privacy Shield Policy ("Policy") describes how Element Six Limited and its subsidiaries and affiliates in the United States ("US") ("Company" "we" or "us") collect, use, and disclose certain personally identifiable information that we receive in the US from the European Union ("EU Personal Data"). This Policy applies to the following US affiliated entities: Element Six Technologies US Corporation and Element Six US Corporation.
Element Six recognizes that the EU has established strict protections regarding the handling of EU Personal Data, including requirements to provide adequate protection for EU Personal Data transferred outside of the EU. To provide adequate protection for certain EU Personal Data about corporate customers and suppliers received in the US, Element Six has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce ("Privacy Shield"). Element Six adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.
For purposes of enforcing compliance with the Privacy Shield, Element Six is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce's Privacy Shield website located at: https://www.privacyshield.gov. To review Element Six's representation on the Privacy Shield list, see the US Department of Commerce's Privacy Shield self-certification list located at: https://www.privacyshield.gov/list
Personal Data Collection and Use
We process EU Personal Data for the purpose of providing the information and services you request as well as for marketing, sales and product development purposes. Element Six will only process EU Personal Data in ways that are compatible with the purpose that Element Six collected it for, or for purposes the individual later authorizes. Before we use your EU Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. Element Six maintains reasonable procedures to help ensure that EU Personal Data is reliable for its intended use, accurate, complete, and current.
Data Transfers to Third Parties
Third-Party Agents or Service Providers. We may transfer EU Personal Data to our third-party agents or service providers who perform functions on our behalf. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process EU Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of EU Personal Data that we transfer to them.
Disclosures for National Security or Law Enforcement
Under certain circumstances, we may be required to disclose your EU Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
Element Six maintains reasonable and appropriate security measures to protect EU Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
You may have the right to access the EU Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EU Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your EU Personal Data to us at Element Six (UK) Ltd., Global Innovation Centre, Fermi Avenue, Harwell Oxford, Didcot, Oxfordshire, OX11 0QR. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EU Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with SpeakUp by Delloitte. If you are unsatisfied with the resolution of your complaint, you may contact SpeakUp by Delloitte at https://www.speak-up-site.com/ for further information and assistance.
Binding Arbitration You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with Element Six and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration).
If you have any questions about this Policy or would like to request access to your EU Personal Data, please contact us as follows: Element Six (UK) Ltd., Global Innovation Centre, Fermi Avenue, Harwell Oxford, Didcot, Oxfordshire, OX11 0QR.
Changes To This Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy Shield's requirements.
Effective date: 30 September 2016
Last modified: 30 September 2016