Effective Date: July 06, 2020
At GearsCRM, Inc., We are committed to protecting Your privacy. This Notice sets out the privacy principles We follow with respect to transfers of personal information from the European Economic Area (“EEA”) and Switzerland to the United States, including personal information we receive from individuals who visit Our web and mobile sites or apps and/or who use any of Our services or otherwise interact with Us (“You”).
We adhere to the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (collectively the “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from the EEA and Switzerland. GearsCRM, Inc. and its group of companies (GearsCRM”, “Us”, “Our” or “We”) commits to apply the Privacy Shield Principles to all personal information received in the United States from the EEA and Switzerland in reliance on the Privacy Shield.
In compliance with the Privacy Shield Principles, GearsCRM, Inc. commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact GearsCRM, Inc. at: privacy@GearsCRM.com
GearsCRM, Inc. has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.
For purposes of enforcing compliance with the Privacy Shield, We are subject to the investigatory and enforcement authority of the US Federal Trade Commission.
For more information about the Privacy Shield, and to view Our certification on the Privacy Shield List, please see the U.S. Department of Commerce’s Privacy Shield website at: www.privacyshield.gov.
Types of Personal Information We Collect and Use
The categories of personal information We may receive in the United States, as well as the purposes for which We collect and use the personal information, are set out in Our Website and Services Privacy Policies, accessible here: www.GearsCRM.com/privacy-policy.
We will only process personal information in ways that are compatible with the purposes We collected it for, or for the purposes You later authorize. Before We use Your personal information for a materially different purpose, We will provide You with the opportunity to opt-out.
Transfers to Third Parties
Information about how We disclose Your personal information to third parties is described in Our Website and Services Privacy Policies, accessible here: https://www.gearscrm.com/privacy-policy/
If We have received Your personal information in the United States and subsequently transfer that information to a third-party acting as an agent, and such third-party agent processes Your personal information in a manner inconsistent with the Privacy Shield Principles, We may be responsible under the Privacy Shield Principles if We are responsible for the event giving rise to the damage.
Disclosures for National Security or Law Enforcement
Under certain circumstances, We may be required to disclose Your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
You may have the right to access personal information that We hold about You and request that We correct, amend, delete it if it is inaccurate or processed in violation of Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of a third party. If You would like to request access to, correction, amendment, or deletion of Your personal information, You can submit a written request to the contact information provided below. We may request specific information from You to confirm Your identity. Because GearsCRM personnel have limited ability to access data Our customers submit to Our Services, if You wish to request access, to limit use, or to limit disclosure, and You are not a direct GearsCRM customer, please provide the name of the GearsCRM customer who submitted Your data to Our services. We will refer Your request to that customer, and will support them as needed in responding to Your request.
You may choose to change personal information or deactivate an account by contacting Us using the contact details below. You can also unsubscribe from Our marketing communications by following the instructions or unsubscribe mechanism in the e-mail message.
Questions or Complaints
You can direct any questions or complaints about the Privacy Shield to Us at privacy@GearsCRM.com or by regular mail addressed to: 10 Kearney Rd, Suite 152, Needham Heights, MA 02494, United States We will respond to any Shield-related complaints or disputes within forty-five (45) days of receipt. If You have an unresolved Privacy Shield concern that We have not addressed satisfactorily, please contact Your EU DPA or the Swiss Federal Data Protection and Information Commissioner, as applicable. The contact details of the EU DPAs can be found here: ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities.
You may also have the option to select binding arbitration for the resolution of your complaint under certain circumstances. To find out more about the Privacy Shield’s binding arbitration scheme please see www.privacyshield.gov/article?id=ANNEX-I-introduction.
Changes to this Notice
We reserve the right to amend this Notice from time to time consistent with Privacy Shield requirements.
Questions about this policy or GearsCRM’s personal data collection, use and disclosure practices, you may contact us by using our contact form. We will use reasonable efforts to respond promptly to requests, questions or concerns you may have regarding our use of your personal data. Except where required by law, GearsCRM cannot ensure a response to questions or comments regarding topics unrelated to this policy or GearsCRM’s privacy practices.