1. Affirmative Statement of Participation in the EU-US Privacy Shield Framework

This statement complies with the EU-US Privacy Shield Framework (‘Privacy Shield’) as set forth by the US Department of Commerce regarding the collection, use, and sharing of personal information transferred from the European Union to the United States.

This Privacy Shield statement describes how Aspectus Inc., (“Aspectus”) collects, uses and transfers data from the EU to the U.S.  Please also refer to Aspectus Privacy Policy https://www.aspectusgroup.com/gdpr-privacy-statement/

2. Jurisdiction

Aspectus Inc.  has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  Aspectus Inc.  confirm that if there is any conflict between the terms of any Aspectus.  Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  Aspectus is also subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).  To learn more about Privacy Shield, please visit www.privacyshield.com

3. Scope

Aspectus participation in the Privacy Shield applies to its colle4ction, use and sharing of personal data that Aspectus collects on behalf of its clients and internal data, e.g. for Human Resources purposes (use where relevant).

Data Collection Processes

Aspectus provides marketing solutions to help its client firms PLEASE COMPLETE AS APPROPRIATE which includes the use of personally identifiable data under the EU Data Protection Laws.

4. Complaints

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

Jed Hamilton, Managing Director, 117 East 24th Street, Suite 2A, NY, NY 10010  646-202-9845

Aspectus has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.

In instances where a complaint has not been resolved by any other means, Aspectus will provide EU data subjects with a b8inding arbitration option before the Privacy Shield Panel.  Aspectus acknowledge that any final decision by Privacy Shield is a legally binding decision, enforceable in U.S. courts.

5. Disclosures to Law Enforcement

Aspectus may disclose in response to lawful requests by public authorities, and to meet national security or law enforcement requirements.

6. Accountability for Onward Transfers

To effectively process data on behalf of a client to serve the client’s needs, Aspectus may need to share that data with certain third parties or sub-processors.  In such instances, Aspectus will execute any contracts, clauses or addendums to ensure that any third-party agents that it engages to process personal data does so in a manner that is consistent with the Privacy Shield Principles.