JnF Specialties PRIVACY SHIELD POLICIES

Effective: May 25, 2018

JnF Specialties (JnF Specialties), (our), (we), or (us) complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Frameworks (together (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Data (as defined below) transferred from European Union member countries and Switzerland to the United States. JnF Specialties has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, JnF Specialties is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Please also see the JnF Specialties Privacy Policies Statement for more information regarding our data handling practices.

Definitions:

In this JnF Specialties Privacy Shield Policy:

(Personal Data) means any information relating to a User that identifies or can be used to identify that User, either separately or in combination with other readily available data that is received by JnF Specialties in the U.S. from the EEA or Switzerland in connection with our Services, including information provided offline, including Sensitive Personal Data.

(Sensitive Personal Data) means Personal Data regarding an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, physical or mental health, or sexual life.

(Services) means JnF Specialties’ websites, hosted applications and related support services.

(User) means an individual who accesses and uses our Services and who resides in the EU or Switzerland.

Scope:

JnF Specialties commits to comply with the Privacy Shield Principles with respect to Personal Data received from Users in connection with the use of our Services. This JnF Specialties Privacy Shield Policy does not apply to Personal Data transferred under Standard Contractual Clauses or any approved derogation under EU data protection law.

Privacy Shield Principles:

JnF Specialties commits to processing Personal Data in accordance with the Privacy Shield Principles as follows:

1. Notice

JnF Specialties’ Privacy Policies informs Users covered by this JnF Specialties Privacy Shield Policy about the categories of Personal Data that JnF Specialties collects and the purposes for collection and use of their Personal Data. JnF Specialties will only process Personal Data in ways that are compatible with the purpose for which JnF Specialties collected it or for purposes later authorized.

The types of Personal Data the JnF Specialties collects from Users depends on the purpose for which each User chooses to use our Services.

When a User processes an online transaction to use our Services, JnF Specialties collects name, email address, and zip code. JnF Specialties also collects billing and shipping information.

When a User submits a request for support, JnF Specialties may collect the following types of Personal Data (some of which is Personal Data) name, telephone number, email address and other information that the User chooses to give us to respond to the support request.

JnF Specialties automatically collects the date and time of the User’s access to our Services. Depending on the settings of a User’s computer or mobile device (“Device”), JnF Specialties also automatically collects: Internet Protocol (IP) address; MAC address; Device make, model and operating system version; mobile network information; internet service provider; browser type and language; country and time zone in which the Device is located; and metadata stored on the Device.

JnF Specialties shares Personal Data collected through our Services with third parties that JnF Specialties engages to provide marketing, billing and similar administrative services.

All Personal Data is collected to operate, manage and improve our Services and ensure the technical functionality and security of our Services. Before JnF Specialties uses Personal Data for a purpose that is materially different from the purpose for which JnF Specialties collected it or that was later authorized, JnF Specialties will provide Users with the opportunity to opt out.

PLEASE SEE THE JnF Specialties PRIVACY POLICIES FOR MORE INFORMATION.

2. Choice

If JnF Specialties collects Personal Data, we will obtain opt-in consent whenever Privacy Shield requires, including if we disclose Personal Data to third parties or before Personal Data is used for a different purpose than that purpose for which it was collected or later authorized.

Please send requests to limit the uses or disclosures of Personal Data to “contact ~at~ qualitycontrolplan.com”.

3. Accountability for Onward Transfer

JnF Specialties may share personal data collected through our Services as follows:

Corporate Transaction: We may share and transfer personal data if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by JnF Specialties or any affiliated company (in each case, whether in whole or in part).

PLEASE SEE THE JnF Specialties PRIVACY POLICIES STATEMENT FOR MORE INFORMATION.

If JnF Specialties transfers Personal Data covered by this JnF Specialties Privacy Shield Policy to a third party, JnF Specialties takes reasonable and appropriate steps to ensure that each third party transferee processes Personal Data transferred in a manner consistent with JnF Specialties’s obligations under the Privacy Shield Principles. JnF Specialties will ensure that each transfer is consistent with any notice provided to Users and any consent they have given. JnF Specialties requires a written contract with any third party receiving Personal Data that ensures that the third party (i) processes the Personal Data for limited and specified purposes consistent with any consent provided by Users, (ii) provides at least the same level of protection as is required by the Privacy Shield Principles, (iii) notifies JnF Specialties if it cannot comply with Privacy Shield; and (iv) ceases processing Personal Data or takes other reasonable and appropriate steps to remediate.

Under certain circumstances, JnF Specialties may be required to disclose Personal Data in response to valid requests by public authorities, including for national security or law enforcement requirements.

JnF Specialties remains liable under the Privacy Shield Principles if an agent processes Personal Data covered by this JnF Specialties Privacy Shield Policy in a manner inconsistent with the Principles unless JnF Specialties is not responsible for the event giving rise to the damage.

4. Security

JnF Specialties takes appropriate measures to protect Personal Data covered by this JnF Specialties Privacy Shield Policy from loss, misuse and unauthorized access, disclosure, alteration, unavailability and destruction. In determining these measures, JnF Specialties takes into account the risks involved in the processing and the nature of the Personal Data.

5. Data Integrity and Purpose Limitation

JnF Specialties takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete and current. JnF Specialties adheres to the Privacy Shield Principles for as long as it retains Personal Data in identifiable form. JnF Specialties takes reasonable and appropriate measures to comply with the requirement under the Privacy Shield to retain Personal Data in identifiable form only for as long as it serves a purpose of processing.

JnF Specialties limits the collection of Personal Data covered by this JnF Specialties Privacy Shield Policy to information that is relevant for processing. JnF Specialties does not process Personal Data in a way that is incompatible with the purpose for which it was collected or subsequently authorized by a User.

6. Access

A User whose Personal Data is covered by this JnF Specialties Privacy Shield Policy has the right to access his or her Personal Data and to correct, amend, limit use of or delete the Personal Data if the Personal Data is inaccurate or processed in violation of the Privacy Shield Principles. JnF Specialties is not required to grant the rights to access, correct, amend and delete Personal Data if the burden or expense of providing access, correction, amendment or deletion is disproportionate to the risks to the User’s privacy or if the rights of persons other than the User are or could be violated.

Please submit requests for access, correction, amendment or deletion to “contact ~at~ qualitycontrolplan.com”.

7. Recourse, Enforcement, and Liability

In compliance with the Privacy Shield Principles, JnF Specialties commits to resolve complaints about your privacy and our collection or use of your Personal Data transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact JnF Specialties at “contact ~at~ qualitycontrolplan.com”.

JnF Specialties has further committed to refer unresolved privacy complaints under the 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, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

JnF Specialties commits to periodically review and verify its compliance with the Privacy Shield Principles and to remedy any issues arising out of failure to comply with the Privacy Shield Principles. JnF Specialties acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of Privacy Shield participants.

Changes to this JnF Specialties Privacy Shield Policy:

JnF Specialties may amend this JnF Specialties Privacy Shield Policy consistent with the requirements of the Privacy Shield, including notice about any amendment.

How to Contact JnF Specialties:

If you have any questions about this JnF Specialties Privacy Shield Policy or would like to request access to your Personal Data, please contact us as follows:

JnF Specialties, LLC
Colorado Springs, CO 80916
Attention: Data Protection Officer
Contact: “contact ~at~ qualitycontrolplan.com”