Privacy Shield

EU-US Privacy Shield Statement

BlueBridge Networks, (“BBN”) 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.  BBN has certified that it 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.  If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  More information is available about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

 

The Federal Trade Commission (FTC) has jurisdiction, investigatory and enforcement powers over BBN’s compliance with the Privacy Shield.
 
This EU-US Privacy Shield Statement applies to data about an identified or identifiable individual that are within the scope of the E.U. Directive, received by BBN from the European Union, and recorded in any form. This includes personal data BBN collects from EU data subjects or receives from its affiliates located in the EU, such as information regarding service requests, service orders, handling orders, for the purpose of delivering services and processing payments. BBN has certified compliance with the EU-US Privacy Shield Framework to the United States Department of Commerce.
 
When BBN acts solely as a data processor on behalf of its customers, BBN acts only on the instructions of its customers and does not control or share such personal data without direction from the customer. BBN's obligations with respect to such personal data, is as defined in its agreements with its customers. BBN receives such personal data from the EU as an agent of the customers. The customers will remain responsible for the personal data that they collect and process and for the compliance with applicable data protection laws.

 

Definitions
"Personal Information" or "Information" means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual. "Sensitive Personal Information" means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual's health.


General

 

Web Server

BBN automatically receives and records information on our web server logs from your browser, including your IP address and the page you request.  BBN does not use this information for any purpose other than internal statistical and analytics purposes.  We may also use third-party website analytics tools (such as Google Analytics) that collect information about user traffic on the Site. 

 

Form Submission

When you proactively submit your contact information in the form of an inquiry or support request, our system stores that information for further communication and interactions.  Though we do not sell or share any of this information with any external 3rd party organizations, BBN may use this information for periodic announcements and promotions unless you explicitly opt out from such communications.

 

E-mail

By sending us an electronic mail (e-mail) message, you may be sending us Personal Information.  In these cases, we may retain the information as long as necessary to respond to your support request or retain the Personal Information to improve our response and resolution 

 

Principles

 

Notice

BBN shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which BBN discloses or may disclose that Information. BBN shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to BBN, or as soon as practicable thereafter, and in any event before BBN uses or discloses the Information for a purpose other than for which it was originally collected.

 

Choice

BBN will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, BBN will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. BBN shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.

 

Onward Transfers

Personal Information obtained by BBN is forwarded only to the end-user, or an agent of the end-user acting on their behalf. BBN will obtain assurances from the end-user or their agents that the information is for the purpose described in the General Section of this policy and that they will safeguard the information obtained. BBN will not actively share/transfer Personal Information to third party controllers or agent/processors.

 

BBN may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

 

BBN’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, BBN remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless BBN proves that it is not responsible for the event giving rise to the damage

 

Data Security

BBN shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. BBN has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. BBN cannot guarantee the security of Information on or transmitted via the Internet.

 

Data Integrity

BBN shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, BBN shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

 

Access

BBN acknowledges that EU individuals have the right to access the personal data that we maintain about them.  An EU individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to BBN’s Privacy and Compliance Officer (contact information can be found below).  If requested to remove data, we will respond within a reasonable timeframe.


Enforcement

BBN uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using (an independent resource mechanism) as a third party resolution provider.

 

In compliance with the Privacy Shield Principles, BBN commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Private Shield policy should first contact BBN at:

 

BlueBridge Networks
Attn: Privacy and Compliance Officer
1255 Euclid Ave., Suite 500
Cleveland Ohio 44115
This e-mail address is being protected from spambots. You need JavaScript enabled to view it.

 

BBN has further committed to refer unresolved Privacy Shield complaints to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus.  If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information or to file a complaint.  The services of BBB EU Privacy SHIELD are provided at no cost to you.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

 

Amendments
This privacy policy may be amended from time to time. We will post any revised policy on this website.

 

Contact Information
Questions, comments or complaints regarding the Company's Privacy Policy or data collection and processing practices can be mailed or emailed to:

BlueBridge Networks
Attn: Privacy and Compliance Officer
1255 Euclid Ave., Suite 500
Cleveland Ohio 44115
This e-mail address is being protected from spambots. You need JavaScript enabled to view it.

 

Opt-Out

You may opt-out of information sharing anytime by emailing us at  This e-mail address is being protected from spambots. You need JavaScript enabled to view it.



 

Updated: 2/22/2017