Screen-Magic, Inc. and the EU-U.S. and SWISS-U.S. Privacy Shield
Screen-Magic, Inc. (“Screen-Magic”) complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield Frameworks”) with the U.S. Department of Commerce regarding the collection and processing of personal data from our advertisers, customers, or business partners in the European Union and, where a Swiss data controller uses Screen-Magic as a data processor, Switzerland (“Partners”) in connection with the products and services described below. To learn more about the Privacy Shield program please visit https://www.privacyshield.gov. The EU-U.S. and Swiss-U.S. Privacy Shield Frameworks were designed by the U.S. Department of Commerce, and the European Commission and Swiss Administration, respectively, to provide companies with a mechanism to comply with data protection requirements when transferring personal data from the European Union and Switzerland to the United States. Both the European Commission and Swiss Government have deemed the Privacy Shield Frameworks as adequate to enable data transfers under EU and Swiss law. Screen-Magic has joined both of the Privacy Shield Frameworks to benefit from these adequacy determinations; and has publicly declared its commitment to comply with the Framework’s requirements.
Screen-Magic commits to adhere to the EU-U.S. Privacy Shield Framework by adopting and implementing the EU-U.S. Privacy Shield Principles, which include a set of Supplemental Principles. Screen-Magic also commits to adhere to the Swiss-U.S. Privacy Shield Framework by adopting and implementing the Swiss Privacy Shield Principles. We will refer to the EU-U.S. and Swiss Privacy Shield Principles collectively as the “Principles.”
Scope: The Privacy Shield Principles (set out in each of the Privacy Shield Frameworks) relates to the collection of personal data, which is information that can be used to uniquely identify you, such as your name, telephone number, address, and e-mail address hereinafter referred to as “Personal Information”). The only Personal Information Screen-Magic may collect is as follows:
1. Information We Collect
1.1 Information You Provide to Us
We collect information about you when you register with us or place an order for products or services. We also collect information when you voluntarily complete customer surveys, provide feedback, and participate in competitions. Website usage information is collected using cookies.
Screen-Magic collects personal information from you, from different sources mentioned below, or when you use any of our web-based products or services.
- Event registrations through a third-party supplier
- Shared by you at our booth at a trade show or event
- Data opt-in forms on website
- Registration for any service
- Information provided to us by third-party data vendors, such as Clearbit
1.2 Information from Other Sources
Screen-Magic receives personal information about you from our third party or business partners with whom we have a contractual relationship. When we get information from a third party, such as your employer, we typically receive limited contact information, and we collect the rest of the personal information directly from you when you interact with us. We may collect the following categories of personal information:
The personal data we may collect is:
|Personal Data Type||Source|
|First Name||Visitor registration/website opt-in forms/exhibitor registrations/publicly available information|
|Last Name||Visitor registration/website opt-in forms/exhibitor registrations/publicly available information|
|Full Postal Address||Visitor registration/website opt-in forms/exhibitor registrations/publicly available information|
|Email Address||Visitor registration/website opt-in forms/exhibitor registrations/publicly available information|
|Telephone||Visitor registration/website opt-in forms/exhibitor registrations/publicly available information|
|Business Email, Title & Employer Contact details||Standard Business Activities|
|Business Job Description||Standard Business Activities|
|Personal information you provide during the recruiting process||Recruitment Activities|
|Employee Information collected during the course of your work for us||From Employees, past and present|
|Website Information gathered via cookies about your activity while visiting our website or interacting with our content and communications||From Marketing Activities|
2. How We Use Your Data
The personal information that we collect is used to perform our contractual obligations, as well as to communicate with you as per your consent based on legitimate needs. We use your personal information for the following purposes:
2.1 Product Services
We use your data for standard business activities.
We use data and content for marketing campaigns and promotions and network growth and engagement.
2.3 Customer Support
We use the data (which can include your communications) to investigate, respond to and resolve complaints and service issues.
2.4 Security and Investigations
We use data for security, fraud prevention and investigations. We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations.
We enable communications between you and others through our SMS Services.
We would also send you messages about the availability of our Services, security, or other service-related issues.
We send messages about promotional campaigns initiated by us or our partners.
We will contact you through email, mobile phone by text messages and push notifications.
You may change your communication preferences at any time. Please be aware that you can opt-out of receiving service messages from us, including security and legal notices. You can reach us at email@example.com.
2.6 Product Enhancement
We use your data, such as feedback, to conduct development of our Products and Services.
3. How We Share Your Personal Information
We may share your information for any of these purposes with the following individuals and entities:
Screen-Magic business partners who sell or deliver our products and services.
Vendors engaged by Screen-Magic to provide certain services on behalf of Screen-Magic, such as marketing services, content management/data storage, and payment processing.
Screen-Magic will never sell, rent, or disclose your personal information to third-party entities except as described in this Privacy Notice.
3.1 Service Providers
We use other vendors to help us provide our Services as part of our product ecosystem. They will have access to your information as reasonably necessary to perform their tasks on our behalf and are obligated not to disclose or use it for other purposes. To the extent Screen-Magic may transfer data to third parties, including any service providers and other partners, Screen-Magic will make reasonable commercial efforts to ensure that any processing of personal data by such third parties is not inconsistent with the Privacy Shield Principles.
3.2 List of Sub-Processors
|Sub-Processor Name||Purpose||Entity Country|
|Amazon Web Services||Hosted storage and processing||United States and EEA|
|Google Inc||Email services and document management to facilitate general business processes and communications with customers and third parties||United States|
|Marketo||Email Campaign system used by the processor to email customers regular updates||United States|
|Stripe||Stripe is a payment gateway that allows our customers to make payments on our website||United States|
|FreshDesk||Help Desk provider the Processor uses to respond to customer support queries||United States|
|Salesforce||Application hosting, authenticatication and communications||United States|
|Clearbit||Customer intelligence||United States|
3.3 Legal Disclosure
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process, or if we have a good faith belief that disclosure is reasonably necessary to:
Investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies, Enforce our agreements with you, Investigate and defend ourselves against any third-party claims or allegations, Protect the security or integrity of our Service (such as by sharing with companies facing similar threats).
We will attempt to notify you about legal demands for your personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge any demand.
4. Enforcement and liability
SCREEN-MAGIC’s participation in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework is subject to investigation and enforcement by the Federal Trade Commission.
In compliance with the Privacy Shield Principles, SCREEN-MAGIC commits to resolve complaints about your privacy and our collection or use of your Personal Data. Data Subjects with inquiries or complaints regarding this Privacy Shield Policy should first contact SCREEN-MAGIC at: at firstname.lastname@example.org Under certain conditions detailed in the Privacy Shield, Data Subjects may be able to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.
SCREEN-MAGIC agrees 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. SCREEN-MAGIC 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.
Screen-Magic has chosen to cooperate with the EU Data Protection Authorities (DPA) under the EU-U.S. Privacy Shield Framework and FDPIC under the Swiss-U.S. Privacy Shield Framework. If you have an unresolved privacy or data use concern that has not been addressed herein, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://edps.europa.eu/node/75 and https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html. Under certain conditions, more fully described on the Privacy Shield website (https://www.privacyshield.gov) you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
6. Data Retention
Screen-Magic retains personal information for as long as we have a legitimate business relationship with you, or with an organization with which you are affiliated (such as your employer). We may also retain personal information about prospective customers or prospective employees until you withdraw your consent, or it has been a period of two years since you’ve provided consent and you no longer have a relationship with us. We also may retain your personal information for as long as necessary to comply with our legal or contractual obligations.
Screen-Magic will process and store personal data for a maximum of two years.
7. Data Integrity and Purpose Limitation
SCREEN-MAGIC limits the collection of Personal Data covered by this Privacy Shield Policy to information that is relevant for the purposes of processing. SCREEN-MAGIC does not process such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the Data Subject.
SCREEN-MAGIC takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. SCREEN-MAGIC 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, which includes SCREEN-MAGIC’s obligations to comply with professional standards, SCREEN-MAGIC’s business purposes and unless a longer retention period is permitted by law, and it adheres to the Privacy Shield Principles for as long as it retains such Personal Data.
8. Accountability for Onward Transfer
In the event we transfer Personal Data covered by this Privacy Shield Policy to a third party acting as a controller, we will do so consistent with any notice provided to Data Subjects and any consent they have given, and only if the third party has given us contractual assurances that it will (i) process the Personal Data for limited and specified purposes consistent with any consent provided by the Data Subjects, (ii) provide at least the same level of protection as is required by the Privacy Shield Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the Personal Data or take other reasonable and appropriate steps to remediate if it makes such a determination. If SCREEN-MAGIC has knowledge that a third party acting as a controller is processing Personal Data covered by this Privacy Shield Policy in a way that is contrary to the Privacy Shield Principles, SCREEN-MAGIC will take reasonable steps to prevent or stop such processing.
With respect to our agents, we will transfer only the Personal Data covered by this Privacy Shield Policy needed for an agent to deliver to SCREEN-MAGIC the requested product or service. Furthermore, we will (i) permit the agent to process such Personal Data only for limited and specified purposes; (ii) require the agent to provide at least the same level of privacy protection as is required by the Privacy Shield Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the Personal Data transferred in a manner consistent with SCREEN-MAGIC’s obligations under the Privacy Shield Principles; and (iv) require the agent to notify SCREEN-MAGIC if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles. Upon receiving notice from an agent that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.
SCREEN-MAGIC remains liable under the Privacy Shield Principles if an agent processes Personal Data covered by this Privacy Shield Policy in a manner inconsistent with the Principles, except where SCREEN-MAGIC is not responsible for the event giving rise to the damage.
9. Your Rights as Data Subject and Choices
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organization.
- Right to object – you have the right to object to certain types of processing, such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review – in the event that Screen-Magic refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 6 below.
Visitors can learn more about how to make these requests here. You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.
EU and Swiss Individual customers may contact Screen-Magic with questions or complaints concerning this Policy at : contacting data-Protection-Officer@screen-magic.com
10. Your Consent
Consent to Processing: Consent to processing is in the form of binary value of “Yes” or ”No”.
Consent Last Updated: We record the value that contains the date and time when the Consent field was updated.
Consent Notes: This value will contain any notes and will capture:
- The purpose of processing for which consent was obtained.
- The way in which consent was obtained (e.g. ticked box online, in person at event).
- Previous consent purposes.
11. Contact Us
In the event that you wish to make a complaint about how your personal data is being processed by Screen-Magic (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Screen- Magic’s data protection representative.
|Contact Name||Data Protection Officer|
|Address 1||Screen-Magic Mobile Media Inc., 2831 St. Rose Parkway, Suite 200, Henderson, NV 89052, USA|
|Address 2||Screen Magic Mobile Media Pvt. Ltd., Office No-201&204, Pride House, Near University Circle, Shivaji Nagar, Pune – 411016, India|
|Contact Number 1||UK: 0-808-189-1305|
|Contact Number 2||US: 1-888-568-1315|