OwnLocal, Inc.  

March 1, 2017

Privacy Policy

Privacy Shield Statement

OwnLocal, Inc. complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. OwnLocal, Inc. has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  If there is any conflict between the policies in this privacy policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern. 

About Privacy Shield:

The “EU-US Privacy Shield” program was established cooperatively by the United States Department of Commerce and the European Commission in 2000. This program sets forth the principles for the transfer of personal information from the European Union (“EU”) to companies operating in the United States.

Participation in the Privacy Shield programs is voluntary for companies operating in the United States. Companies participating in the Privacy Shield programs annually self-certify compliance with privacy standards adopted by the EU Commission and the United States Department of Commerce.

Scope:

This Privacy Shield Statement governs personal information transferred from countries in the EU to the United States and in connection with OwnLocal, Inc. business activities.

For the purpose of Privacy Shield, “personal information” shall mean any information which may, directly or indirectly, identify or lead to the identification of a person or entity. Personal information shall include, but is not limited to, an individual’s name, address, email address, telephone number, government identification number, license numbers of any kind, or photographs. Personal information shall not include information that is anonymous, stripped of identifying details, encoded or encrypted, or aggregated. Personal information also shall not include any information that is publicly available, except where such public information is supplemented with non-public, personally identifying information.

Privacy Shield Privacy Principles

The following principles form the core of the Privacy Shield programs:

Notice:

Any personal information received by OwnLocal, Inc. in connection with its business is provided voluntarily by persons having “ownership” of such information. OwnLocal, Inc. provides persons with an explanation about the types of information collected or maintained, how such information is maintained and protected, and how to contact OwnLocal, Inc. to request review, correction or deletion of such information. Personal information is never disclosed to a third party without consent of the affected individual(s).

OwnLocal, Inc. also maintains a Privacy Statement on its corporate website which outlines the collection and use of any information collected from persons visiting such websites.

In certain limited cases and only where authorized by Privacy Shield principles, OwnLocal, Inc. may be unable to provide notice of disclosure of personal information to affected person(s). For example, Privacy Shield principles do not require notice where disclosure of personal information is required to comply with a court or other valid government order or inquiry, where applicable laws or regulations waive notice requirements, or where protection of legitimate OwnLocal, Inc. legal interests would be compromised by notice.

Choice:

OwnLocal, Inc. will not use any personal information collected from or about covered individuals for any purpose not authorized by the individual. For the purpose of this section, voluntary provision of personal information in connection with the performance of certain activities will constitute authorization as will a written statement granting permission to use or disclose information for certain stated purposes. Individuals may contact OwnLocal, Inc. at any time to inquire about the types of personal information OwnLocal, Inc. currently maintains and to request either changes in authorized uses or deletion of their personal information from OwnLocal, Inc. records.

Data Integrity:

OwnLocal, Inc. strives to ensure that any personal information collected or maintained about covered individuals is complete, accurate and reliable for the purposes for which the information was obtained or authorized.

Transfers to Third Parties:

OwnLocal, Inc. does not share personal information collected with any third parties without consent.

Access and Correction:

Covered individuals may contact OwnLocal, Inc. in writing to request reasonable access to their personal information. OwnLocal, Inc. will take reasonable steps to allow such individuals to review, correct or request deletion of their personal information.

Security:

OwnLocal, Inc. has implemented a variety commercially reasonable physical security and information technology measures to protect personal information. Such security measures are supplemented by operational procedures and staff training.

Enforcement:

OwnLocal, Inc. has established internal management practices and policies to support the Privacy Shield principles. OwnLocal, Inc. encourages covered individuals with concerns about its information management practices to contact OwnLocal, Inc. at the address below. OwnLocal, Inc. also has agreed to participate in dispute resolution programs provided by the Better Business Bureau.

Limitation on Scope of Principles:

OwnLocal, Inc. will take all reasonable steps to comply with Privacy Shield principles and this policy. Strict compliance with Privacy Shield or these policies may be limited in certain cases and as required to meet legal, governmental or national security obligations. Information about limitations is set forth in the U.S. Department of Commerce Privacy Shield website.

Contact Information:

In compliance with the EU-US Privacy Shield Principles, OwnLocal, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this privacy policy should first contact OwnLocal, Inc.:

By post:

General Counsel

OwnLocal 

205 W. 9th St

Suite 600

Austin, TX USA 78701

By email:

privacy@OwnLocal.com

OwnLocal, Inc. has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by OwnLocal, Inc., please visit the BBB EU Privacy Shield web site for more information.