Effective Date: January 15, 2019
What information we collect
How we use that information
How we may share that information
How we protect your information
2mclean® Technologies, Inc. participates in the EU-US and Swiss-US Privacy Shield Frameworks. To learn more about this program and our participation in this program, click here.
I. INFORMATION WE COLLECT
a) Personal Information You Give Us
We collect information that you voluntarily share with us through the 2mclean® Platform.
If you are using the 2mclean® Platform to request professional services, or contact 2mclean® or its third-party service providers, you may give us:
If you are a service professional using 2mclean®'s web booking for service professionals we may collect your geographic location by using Global Positioning System (GPS).
We only collect location information about service professionals who have been accepted to participate on the 2mclean® booking and not about service requesters or about service professionals applying to participate in the 2mclean® Booking Platform.
Contact information, such as your name, physical address, telephone number, and email address
Information about your home, such as the number of bedrooms, the types of appliances, zip code or postal code where your home is located and your instructions for servicing your home
Billing information, such as credit or debit card number, expiration date & security code and/or information regarding your PayPal, Google Wallet or other digital payment accounts and the 2mclean® Platform itself
Ratings and reviews of the service professionals you engage through the 2mclean® Platform
If you participate on the 2mclean® Platform as a service professional, or contact 2mclean® or its third-party service providers, you may give us:
Contact information, such as your name, email address, mailing address, and phone number
Social Security number, if you are a service professional who wishes to participate on the 2mclean® Platform in the United States and you are selected for a background check
If you apply on the 2mclean® Platform for employment with 2mclean®, you may give us:
Contact information, including your name, email address, telephone number, and mailing address
Resume and LinkedIn profile
More about payment card information:
Although users can submit credit card or other payment card information to pay for a service through the 2mclean® Platform, 2mclean® does not receive this information itself. Payment card information is transmitted directly to a third-party payment card processor, Stripe, through an Internet connection secured by industry-standard Transport Layer Security (TLS) encryption technology. Stripe then communicates to 2mclean® whether your payment has cleared, but does not provide payment card information to 2mclean®.
You may, at your choice, complete surveys on the 2mclean® Platform or distributed by 2mclean® about, for example, your level of satisfaction with the 2mclean® Platform, your engagement with the 2mclean® Platform, and your awareness of 2mclean® Platform features. In some cases, we may link the information you provide in the survey with Personal Information in your 2mclean® account, such as your name or email address. When linked to Personal Information, your survey information becomes Personal Information too.
b) Information We Collect Through Technology
We collect information through technology to enhance our ability to serve you. When you access and use the 2mclean® Platform, or contact 2mclean® or its third-party service providers, 2mclean® and, in some cases, our third-party service providers collect information about you or how you interact with the 2mclean® Platform. We describe below a few of the methods we use to collect information through technology.
When you visit the 2mclean® Platform, we collect your Internet Protocol (IP) address. An IP address is often associated with the portal you used to enter the Internet, like your Internet service provider (ISP), company, association, or university. While an IP address may reveal your ISP or geographic area, we cannot determine your identity solely based upon your IP address. However, we may link the last IP address you used to access the 2mclean® Platform to Personal Information you provide us. Where, according to local law, IP addresses and the like are considered Personal Information, we treat them as such.
We may also collect a unique identifier for your computer, mobile device, or other device used to access the 2mclean® Platform ("Device Identifier"). A Device Identifier is a number that is automatically assigned to the device you used to access the 2mclean® Platform. We may link the Device Identifier to other information about your visit, such as what pages you viewed, and to Personal Information you provide us, such as your name.
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select "Remember Me", your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
We may include small graphic images or other web programming code, called web beacons (also known as "pixel tags", "web bugs" or "clear GIFs"), in our web and mobile pages and messages. The web beacons are minute graphics with a unique identifier. They are used to track the online movements of Web users. In contrast to cookies, which are stored in a user's computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. Web beacons help us better manage content on the 2mclean® Platform by informing us what content is effective, monitoring how users navigate the 2mclean® Platform, counting users of the 2mclean® Platform, and counting how many e-mails sent by us were actually opened.
Your 'Do Not Track' Browser Setting
We do not support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser's settings to let the websites you visit know that you do not want the websites collecting your Personal Information.
We do track your online activities over time and across third-party websites or online services. For example, we use web beacons to help us determine what links or advertisers brought you to our Site. We also use third-party service providers to display advertisements to you on other websites based on your activities while on the 2mclean® Platform.
c) Information Collected by Mobile Applications
When you use the App, the App may automatically collect and store some or all of the following information from your mobile device ("Mobile Device Information"), including, but not limited to:
The type of Internet browsers you use with the App.
Your preferred country site.
Your mobile operating system.
Your phone number or other identifiers assigned to your mobile device, including: The IP address of your mobile device, The manufacturer and model of your mobile device
We may also collect information about how you use the App, such as the amount of time you spend using the App, how many times you use a specific feature of the App over a given time period, how often you use the App, and actions you take in the App. In addition, we may gather information about the website from which you downloaded the App to help us determine what App download site is most effective (collectively "App Usage Information").
We may link your Mobile Device Information and App Usage Information to Personal Information you have provided us, in which case we will treat the combined information as Personal Information.
If you are a service professional using 2mclean®'s mobile application for service professionals (the "Pro Portal"), we may collect your geographic location by using Global Positioning System (GPS) information sent to us from the Pro Portal. For more information on when this information is collected, how we use it, and with whom it is shared, services professionals should refer to the Service Professional Agreement available on the service professional portal.
We only collect location information about service professionals who have been accepted to participate on the 2mclean® Platform and not about service requesters or about service professionals applying to participate in the 2mclean® Platform.
d) Information You Provide About A Third Party
If you choose to use our referral service to tell a friend about the 2mclean® Platform, we may collect your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the 2mclean® Platform. We store this information only to send this one-time email and to track the success of our referral program. We do not use this information for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you refer a friend, your e-mail address may be included in the message sent to your friend.
If you are using the 2mclean® Platform to request professional services, you may provide us ratings and reviews of the service professionals you engage through the 2mclean® Platform.
e) Information Third Parties Provide About You
Conversion Tracking: We may supplement the information we collect about you through the 2mclean® Platform with records received from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you. For example, websites on which we have placed advertisements, such as Google, may tell us which ads about 2mclean® you clicked. This is often called "conversion tracking."
Background Checks: In addition, when third parties such as Hirease, Onfido or Checkr.com conduct background checks on service professionals, those third parties share the results of the background check with 2mclean®.
Recording Phone Calls: Selected third-parties, including those who may assist in providing customer service support, may monitor and/or record the contents of phone calls made through or in relation to the 2mclean® Platform, after notice to you and with your consent.
Social Networking Sites: If you login to the 2mclean® Platform through a social networking site, such as Facebook, we may collect your Facebook authentication token and account identification number and use that information to provide you with access to your account on the 2mclean® Platform.
Ratings and Reviews: If you are using the 2mclean® Platform as a service professional, we may receive information about you in the form of ratings and reviews from requesters who engaged your professional services through the 2mclean® Platform.
Photographs of Completed Services: If you are using the 2mclean® Platform to request services, service professionals booked through the 2mclean® Platform may take photographs of completed services and provide them to 2mclean®.
Message Interception: If you call or text (SMS) message a service professional or service requester using the telephone number provided by 2mclean®, 2mclean® uses Twilio to mask your telephone number. During this process, 2mclean® and Twilio receive in real time and store call data, including the date and time of the call or text (SMS) message, the parties’ phone numbers, and the content of the text (SMS) messages.
If you send a message to a service professional or service requester in the App, 2mclean® uses Layer to process the communications. During this process, 2mclean® and Layer receive in real time and store message data, including the date, time, and content of the messages.
If you are using the 2mclean® Platform as a service professional, we may receive information about you in the form of ratings and reviews from Requesters who engaged your professional services through the 2mclean® Platform.
f) Information You Provide to a Third Party
The 2mclean® Platform includes links from the 2mclean® Platform to sites or applications operated by third parties ("Third-Party Sites") and plug-ins (such as Twitter buttons) from Third-Party Sites.
For example, service professionals may be directed to a Third Party Site, such as Checkr.com, Onfido.com, SterlingTalentSolutions.com, or Hirease.com, so that the Third Party Site can conduct a background check. The Third Party Site may ask the service professional for identifying information to conduct the background check.
Some Third-Party Sites link to 2mclean® and share information with 2mclean®. For example, in some cases, you can book services through the 2mclean® Platform with one of our booking partners (“Booking Partner”), such as Amazon, Facebook, Walmart and Wayfair. In that case, you might provide the booking information, such as your name, telephone number, email address, and booking address, to the Booking Partner. The Booking Partner might then share the necessary booking information with us.
II. HOW WE USE THE PERSONAL INFORMATION WE COLLECT
We – including without limitation our affiliates, parents, and subsidiaries – use the information we collect to serve our customers, consider applicants, market and promote our services, and improve your experience at the 2mclean® Platform. Some examples include:
Scheduling, rescheduling, and cancelling services
Rating and reviewing service professionals
Providing public profiles of service professionals
Addressing service complaints
Communicating with you by email, telephone, or text message, in accordance with your wishes
Managing payments for services
Considering whether to engage service professionals on the 2mclean® Platform
Evaluating job applications to work at 2mclean®
Improving customer service
Sending you marketing and promotional emails, on behalf of 2mclean® or selected third parties, unless you have told us you do not want to receive such emails
Troubleshooting technical problems on the 2mclean® Platform
Responding to questions and feedback
Conducting research and analysis
Running online or mobile sweepstakes, contents, or other promotions
Marketing and advertising 2mclean® products and services and those of selected third parties
Continuously evaluating and improving the online and mobile user experience
Contacting you with regard to your use of the 2mclean® Platform and, in our discretion, changes to the 2mclean® Platform and/or the 2mclean® Platform policies
Compliance with the law or to protect the rights, property, or safety of 2mclean®, our users, or others, including to maintain network and information security, for fraud prevention, and to report suspected criminal acts
By using the 2mclean® platform, you expressly consent and agree to accept and receive communications from us, including via text message, calls, and push notifications to the cellular telephone number you provided to us. Standard text messaging charges applied by your cell phone carrier will apply to text messages we send. By consenting to being contacted by 2mclean®, you understand and agree that you may receive communications, including marketing communications generated by automatic telephone dialing systems and/or which will deliver prerecorded messages, sent by or on behalf of 2mclean®, its affiliated companies and/or Users/Professionals, including but not limited to: operational communications concerning your account or use of the 2mclean® Platform or Services, updates concerning new and existing features on the 2mclean® Platform, communications concerning promotions run by us, and news concerning 2mclean® and industry developments. You acknowledge that you are not required to consent to receive promotional messages as a condition of using the 2mclean® Platform or the Services. If a contact number you have provided to us is no longer your number, you agree to notify us promptly that you can no longer be reached at that number. You represent that you have received, and are authorized to convey to us, the consent of any authorized users on your account to be contacted by us as described in this Section. You agree that all consents provided in this Section will survive cancellation of your account. You may opt-out of receiving promotional or marketing texts or calls from 2mclean® at any time. You may opt-out of receiving all text (SMS) messages from 2mclean® (including informational or transactional messages) by replying with the word “STOP” to a text message from us; however you acknowledge that opting out of receiving all texts may impact your use of the 2mclean® Platform or the Services. You also acknowledge that 2mclean® or its third party service providers may record customer service calls after notice to you and with your consent, in order to assist you when you contact our customer support services.
You agree to 2mclean®’s use of a service provider to mask your telephone number when you call or exchange text (SMS) messages with a Service Professor or Service Requestor using a telephone number provided by 2mclean®. During this process, 2mclean® and its service provider will receive in real time and store call data, including the date and time of the call or text (SMS) message, the parties’ phone numbers, and the content of the text (SMS) messages. You agree to the masking process described above and to 2mclean®’s use and disclosure of this call data for its legitimate business purposes.
The information described in this section may be transferred to, or processed and stored in, the United States and other countries, which may employ greater or less restrictive data protection laws. In all cases, we will take appropriate measures to protect your personal information in accordance with the policies described herein.
We delete the back-ups of the databases containing your Personal Information after 13 months.
III. HOW WE SHARE THE INFORMATION WE COLLECT
The following are some examples of how we share your information with third-party service providers.
Data Analytics. We retain third-party service providers to help us perform data analytics regarding your interactions with the 2mclean® Platform. For example, Google Analytics and Bounce Exchange may track what pages users visit on the Site, whether users use any coupon codes, and what services users request to determine how users use the Site. For example, Branch Metrics and Mixpanel collect and provide reports to us showing how you interact with the 2mclean® Platform using information, such as your IP address, browser ID and Device Identifier.
In some cases, these third-party service providers, such as Epsilon, may in turn share your Personal Information, such as your name and email address, with other third parties for their marketing-related purposes.
Platform Features. Service providers help us to provide functions available through the 2mclean® Platform. For example, we may share your Device Identifier with Urban Airship so that it can help us to send you push notifications. We share your telephone number and call data with Twilio, as described in Section I(e), above, so that Twilio can mask your telephone number. We share your telephone number, call data, device id and other 2mclean® account and device information with Layer, as described in Section I(e), above, to help facilitate communication using the App.
Payment Processing. We use Stripe, a third-party service provider, to process any billing information, including credit card information you submit.
User Reviews Aggregation. We use third-party service providers, such as Bazaarvoice, to aggregate user reviews and publish them on third party websites.
Email Delivery. We use third-party service providers, such as Customer.io and Sendgrid, to deliver email to our users.
Background Check Service Providers. When service professionals applying to participate on the 2mclean® Platform in the United States provide their Social Security numbers for a background check, the Social Security number is transmitted using TLS encryption to the background check service provider. 2mclean® also securely provides U.S. service professional's Social Security numbers to the check processor.
Marketing and Promotional Vendors and Partners. We may share Personal Information with third party service providers who assist us with marketing, and with other trusted parties whom we believe offer products or services that may be of interest to you.
Digital Vault Services. If you participate in 2mclean® Vault, 2mclean® uses KeyCafe, a third-party service provider, to store and provide digital access for your keys to services professionals participating on the 2mclean® platform. As part of this service, 2mclean® will provide KeyCafe your name and your physical keys. If you provide services to a customer who participates in 2mclean® Vault, 2mclean® uses KeyCafe, a third-party service provider, to provide digital access to the customer's keys. As part of this service, 2mclean® will provide KeyCafe your mobile phone number.
Customer Support. We use third-party service providers to assist with providing customer support for questions you may have about your account and use of the 2mclean® Platform. We may disclose your Personal Information to such service providers to assist with responding to your questions.
Legal Advice. We may disclose your Personal Information to an attorney in the process of obtaining legal advice.
d) Banks and Credit Card Companies
We may disclose your Personal Information to banks and credit card companies in the process of investigating payment fraud and/or responding to disputed charges.
e) Third Parties Providing Information on Available Services or Marketing Offers
f) Booking Partners
We share your Personal Information with Booking Partners. For example, Amazon, Facebook, Wayfair and Walmart customers can book services through the 2mclean® Platform from the Amazon, Facebook, Wayfair and Walmart, including those customers in the United Kingdom, sites and apps. Upon request, we provide our Booking Partner with information about the services you booked or provided, as applicable, through the 2mclean® Platform.
g) Sweepstakes, Contests and Promotions
We may offer sweepstakes, contests, and other promotions (any, a "Promotion") through the 2mclean® Platform that may require providing Personal Information to register. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. Please read the official rules carefully. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners' list.
h) Social Network Site Authentication
If you choose to log-in to the 2mclean® Platform through Facebook, Twitter, or another social networking site, we may share information about your account with the social networking site.
i) Administrative and Legal Reasons
We may be required to disclose Personal Information in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
Legal Compliance and Protections:
We may disclose account and other Personal Information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of 2mclean®, our users, or others. This includes exchanging Personal Information with other companies and organizations for fraud prevention and credit risk reduction.
h) Corporate Transactions
We reserve the right to disclose and transfer your information, including your Personal Information:
To a subsequent owner, co-owner, or operator of the 2mclean® Platform or successor database.
In connection with a corporate merger, consolidation, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.
CHILDREN'S ONLINE PRIVACY PROTECTION ACT COMPLIANCE
We do not collect any information from anyone under 13 years of age. The 2mclean® Platform, and products and services offered through it, are all directed to people who are at least 13 years old or older. If you are under the age of 13, you are not authorized to use the 2mclean® Platform.
IV. HOW WE PROTECT THE PERSONAL INFORMATION WE COLLECT
The security and confidentiality of your Personal Information is important to us. We have implemented technical, administrative, and physical security measures to protect your Personal Information from unauthorized access or disclosure and improper use.
For example, when users book services, the information they input is encrypted through TLS encryption. We do not store credit card information on our servers, and we use TLS encryption to protect your credit card information when it is transferred to our third-party payment processor. In addition, access to your Personal Information is restricted in our offices. Only employees who need the Personal Information to perform a specific job, for example, sales representatives, managers, and customer service staff, are granted access to Personal Information. All employees with access to Personal Information are kept up-to-date on our security and privacy practices. After a new policy is added, these employees are notified and/or reminded about the importance we place on privacy, and what they can do to enhance protection for our users' Personal Information.
It is important for you to protect against unauthorized access to your account password and to your computer. Be sure to log out of your account or to close your browser after you have completed your visit to our Site.
Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your Personal Information.
V. YOUR CHOICES REGARDING THE INFORMATION WE COLLECT
You may contact firstname.lastname@example.org to update, correct, or delete your Personal Information. You may also update, correct, and delete some of your Personal Information through your account on the 2mclean® Platform.
In addition, you may cancel or modify the email communications you have chosen to receive from the 2mclean® Platform by following the instructions contained in emails from us.
VI. HAVE QUESTIONS?
2mclean® Technologies, Inc.
a) All locations outside of the United States
The Personal Information collected through the Site is downloaded to a server maintained by 2mclean® in the United States. 2mclean® will comply with requests to exercise individual data rights in accordance with applicable law. You can contact email@example.com to request to exercise your data rights.
b) For Individuals in the EU
To provide an adequate level of protection for Personal Information received from the Member States of the European Economic Area ("EEA") and from Switzerland, 2mclean® Technologies, Inc., ("2mclean® US") complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce (“Privacy Shield Principles”) when processing the Personal Information of natural persons located in the EEA and Switzerland (collectively, "EEA Individuals") whose data is transferred into the US pursuant to the Privacy Shield. EEA Individuals include users of the 2mclean® Platform, such as service requesters and service professionals. EEA Individuals also include employees of 2mclean® US’ affiliated companies located in the Member States. Please note that service professionals who provide services through the 2mclean® Platform are independent contractors and are not employees of 2mclean® US or employees of any of 2mclean® US’ affiliated companies, including those located in the Member States.
c) Notice 2mclean® US's Use And Disclosure Of Personal Information
2mclean® US receives the Personal Information of applicants for employee positions located in the Member States and Switzerland ("Applicants")to administer the recruitment process and, of employees, to administer the employment relationship. Examples of the purposes for which 2mclean® US collects and uses employee and Applicant Personal Information include, without limitation, recruitment; workforce management; to administer compensation, payroll, and benefits; to address various legal obligations related to the employment relationship, including discovery obligations in civil litigation; to administer training; to administer 2mclean® US’ compliance process; and for emergency contact purposes.
The employee and Applicant Personal Information that 2mclean® US receives from the EEA and Switzerland consists largely of information provided by Applicants, such as resumes and completed job applications and information created by 2mclean® US or its affiliates to administer the employment relationship, such as business contact information, and compensation and benefits information.
2mclean® US may disclose employee and Applicant Personal Information, subject to written agreement, to authorized service providers who provide services related to the administration of the recruitment process and/or the employment relationship. 2mclean® US also may disclose employee and Applicant Personal.
Information to corporate affiliates in connection with the recruitment process and for internal employment administration purposes, such as to administer access to physical facilities and information systems and for succession planning.
2mclean® US may be required to disclose, and may disclose, EEA and Swiss Personal Information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements.
d) Cross-Border Data Transfers:
The Personal Information collected through the Site will be transferred to the United States. The recipients of Personal Information collected through the Site (listed in Section III above) are located in the United States and the Philippines or in the country where the data was collected and the data that is transferred will be subject to Privacy Shield.
e) Legal Bases For Processing:
Consent and as Required by Law: 2mclean® processes your Personal Information with your consent and as required by law.
Contract: Users can enter into two different types of contracts through the 2mclean® Platform: (1) a contract between service requesters and service professionals regarding professional services, and (2) a contract between the user and 2mclean® whereby 2mclean® facilitates the arrangement of the professional services contract in exchange for a share of the fee for the contracted professional services. To take steps necessary to respond to users’ requests to enter into both types of contracts, 2mclean® processes Personal Information from service requesters, including contact information, services requested, and worksite location information, and from service professionals, including contact information, skills and experience, background check information, preferred times, and preferred locations. To facilitate the performance of the service professional agreement and to perform the contract with users, 2mclean® must process Personal Information, including the service requester’s billing information, the service professional’s receivables information and geographic location information, and both parties’ text messages and phone calls through the 2mclean® Platform.
2mclean® cannot facilitate service professional contracts through the 2mclean® Platform or enter into contracts with users unless users provide this Personal Information.
Legitimate Interests: 2mclean® also processes Personal Information as necessary for its legitimate interests as follows:
Marketing and advertising: Unless you opt out as described below, we use your Personal Information as necessary to provide you information about the services that we think might interest you, in accordance with applicable law.
Network and information security, fraud prevention, and reporting suspected criminal acts: In the event of fraud, a security incident, or a suspected criminal act, we would examine Personal Information that appeared to be linked to the incident as necessary to determine what happened, remediate, report to the authorities, and prevent a recurrence.
Right to Object to Processing for Direct Marketing or Legitimate Interests:
EEA Individuals have the right to object to the processing of their Personal Information for purposes of 2mclean®’s direct marketing or legitimate interests by contacting 2mclean® at firstname.lastname@example.org
2mclean® sometimes uses EEA Individuals’ Personal Information submitted through the Site for automated decision-making. For example, 2mclean® may display advertisements and send emails to you containing content automatically chosen based on the services you have ordered through the 2mclean® Platform in the past. However, 2mclean® will not use EEA Individuals’ Personal Information submitted through the Site for automated decision-making, including profiling, which produces legal effects or similarly significantly affects the EEA Individual.
EEA Individuals have the right to access their Personal Information collected by the Site and to request that 2mclean® update, correct, or delete their Personal Information as provided by applicable law. EEA Individuals also have the right to object to, or restrict, 2mclean®’s processing of their Personal Information.
In addition, EEA Individuals have the right to data portability concerning their Personal Information. Subject to certain limitations, the right to data portability allows EEA Individuals to obtain from 2mclean®, or to ask 2mclean® to send to a third party, a digital copy of the Personal Information that they provided to the Site. EEA Individuals’ right to access their Personal Information includes their right to receive a copy of all, or a portion, of their Personal Information in 2mclean®’s possession as long as 2mclean®’s providing the Personal Information would not adversely affect the rights and freedoms of others.
f) Choice: How To Opt Out Of Collection Of Your Personal Information By 2mclean® US And Transfer To Third Parties
2mclean® US will offer EEA Individuals whose Personal Information has been transferred to the United States pursuant to the Privacy Shield the opportunity to opt out from: (a) the disclosure of their Personal Information to any non-agent third parties not already listed in Section III above and (b) the use of their Personal Information for purpose(s) that are not compatible with the purpose(s) for which the Personal Information was originally collected or subsequently authorized by the Individual. 2mclean® US will provide EEA Individuals with clear, conspicuous, and readily available mechanisms to exercise choice. should such circumstances arise. Any withdrawal will apply only prospectively, and 2mclean® will continue to retain the Personal Information that EEA Individuals provided before they withdrew their consent for as long as allowed or required by applicable law.
g) Access And Correction: How You Can Exercise Your Rights
2mclean® US acknowledges EEA Individuals’ right to access and correct their Personal Information. Upon reasonable request, 2mclean® US will grant EEA Individuals reasonable access to their Personal Information and will permit them to correct, amend or delete Personal Information that is inaccurate or incomplete. EEA Individuals wishing to exercise these rights may do so by contacting email@example.com Employees should contact their local manager to exercise these rights.
h) Enforcement: What To Do If You Have a Complaint
In compliance with the Privacy Shield Principles, 2mclean® US commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact 2mclean® US at firstname.lastname@example.org.
2mclean® US 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.
2mclean® US commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by the EU DPA’s and Swiss FDPIC with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
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
Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. Contact details for the Swiss Federal Data Protection and Information Commissioner can be found at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection---switzerland.html
In compliance with the Privacy Shield Principles, 2mclean® US commits to resolve complaints about our collection or use of employees’ Personal Information. Current or former employees with inquiries regarding the Privacy Shield or who wish to submit a complaint concerning the handling of their Personal Information should first contact 2mclean® US at: email@example.com. Current or former employees who are not satisfied with the internal resolution of a complaint may seek redress from the panel established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner (the “Commissioner”), as applicable. 2mclean® US will cooperate in investigations by, and comply with the advice of, the panel and/or Commissioner with regard to an employee’s Personal Information transferred from the EU and/or Switzerland in the context of the employment relationship.
2mclean® US is subject to the jurisdiction and enforcement authority of the U.S. Federal Trade Commission (FTC).
2mclean® US may be liable for the onward transfer of EEA and Swiss Personal Information to agent third parties pursuant to the Privacy Shield unless we can prove that we were not a party to the actions giving rise to the damage.