General. We rely on our Privacy Shield certification to transfer Personal Data that we receive from the EU to Sidekick in the U.S. and we process such Personal Data in accordance with the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability (“Privacy Shield Principles”), as described below.
Choice. You may opt out of (i) the disclosure of your Personal Data to third parties that do not provide services to us and/or (ii) uses of your Personal Data for purposes that are materially different from the purposes for which the Personal Data was collected provided that such purposes have not been authorized by you. To exercise these rights, please email firstname.lastname@example.org. Please see the “Your Choices” section of this policy for additional information.
Accountability for Onward Transfers. We may be accountable for the Personal Data we receive under the Privacy Shield that we may transfer to third-party service providers (described in the “Our Disclosure of Your Personal Data and Other Information” section below). If we are and our third party service providers process Personal Data in a manner inconsistent with the Privacy Shield Principles, we are responsible and liable for the harm caused, unless we prove that we are not responsible for the event giving rise to the damage.
Security. We maintain security measures to protect Personal Data as described in the “Security” section below.
Data Integrity and Purpose Limitation. We take reasonable steps to ensure that Personal Data is reliable for its intended use, and that it is accurate, complete and current for as long as we retain it. We will retain the data as long as necessary for the following purposes: delivering the Services, engaging in customer service, complying with legal obligations, auditing, performing security and fraud prevention, responding to legal and regulatory inquiries, and preserving or defending our legal rights or those of other users or third parties.
Access. Individuals in the EU have certain rights to access, correct, amend, or delete Personal Data where it is inaccurate, or has been processed in violation of the Privacy Shield Principles. To exercise these rights please email email@example.com. When we process your Personal Data as a data processor on behalf of our customers, we will process such requests pursuant to our contracts with our customers and our customers’ instructions.
Recourse, Enforcement, Liability. In compliance with the Privacy Shield Principles, Sidekick commits to resolve complaints about our processing of your Personal Data. Individuals in the EU with inquiries or complaints regarding this Private Shield Policy should first contact Sidekick as follows:
Attention: Privacy Shield
Postal Mail: Sidekick Coaching Technologies, Inc., ℅ Wework 750 N. San Vicente Blvd., Los Angeles, CA 90069
We have further committed to refer unresolved Privacy Shield complaints to an alternative dispute resolution provider. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider The International Centre for Dispute Resolution-American Arbitration Association (ICDR-AAA), at http://go.adr.org/privacyshieldfund.html (free of charge).
Notwithstanding the foregoing, in relation to complaints relating to Personal Data of Sidekick employees that cannot be resolved directly with Sidekick, we have committed to working with the panel established by EU data protection authorities (“DPAs”) and complying with the information and advice given by the panel of DPAs regarding HR data transferred to the U.S. from the EU in accordance with the Privacy Shield Principles. Please contact us at firstname.lastname@example.org to be directed to the relevant DPA’s contacts and, for additional information, please visit https://www.privacyshield.gov/article?id=5-The-Role-of-the-Data-Protection-Authorities-a-b.
If your complaint is not resolved through the channels described above, under certain conditions a binding arbitration option may be available before a Privacy Shield Panel. For additional information, please visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
We are subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to Personal Data received or transferred pursuant to the Frameworks.
Information We Collect:
When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:
Personal Data That You Provide Through the Services:
Non-Identifiable Data: When you interact with Sidekick through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Sidekick may store such information itself or such information may be included in databases owned and maintained by Sidekick affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.
Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services, Sidekick often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Sidekick may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Sidekick may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Our Use of Your Personal Data and Other Information:
Our Disclosure of Your Personal Data and Other Information:
Sidekick is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Agents, Consultants and Related Third Parties: Sidekick, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements: Sidekick may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend the rights or property of Sidekick, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
Disclosures to Employer: Employers create a corporate Sidekick account in order to use the Services and provide the Services to their Employees. We may share certain Personal Data with the Employee’s Employer, such as the Employee’s name and information about Employee’s interaction with the Services, including the results of our standardized survey that measures the Employee’s level of engagement at work, following the Sessions provided through the Services.
Whether or not you provide Personal Data to us is completely up to you, but if you choose not to provide information that is needed to use some features of our Site, you may be unable to use those features. You can also contact us to request access to your data or to ask us to update, correct, or delete your Personal Data.
Links to Other Web Sites:
Sidekick takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Sidekick via the Internet.
Other Terms and Conditions:
Your access to and use of the Services is subject to the Terms of Service at http://sidekick-hq.com/terms-of-service.
Access to Information; Contacting Sidekick:
To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.
You may contact us as follows:
Sidekick Coaching Technologies, Inc.
C/O Wework, 750 N. San Vicente Blvd