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Effective: February 4, 2020
Panorays Inc. (“Panorays”, “We”
or “Our”) has certified with the EU-U.S. Privacy Shield and the
Swiss-U.S. Privacy Shield with respect to the Personal Data (defined
below) that We receive from the Customers (defined below) or from Panorays Ltd.
Panorays complies with the principles of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred to the United States. Panorays has certified to the Department of Commerce that it adheres to the Privacy Shield Principles and Our Privacy Shield certification, when approved, will be available here. If there is any conflict between the terms in this Privacy Shield Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/welcome.
“Customer(s)” means prospective,
current, or former customers, or clients of Panorays and/or Panorays Ltd.
“Personal Data” means any information
relating to an identified or identifiable natural person; an identifiable
natural person is one who can be identified, directly or indirectly, in
particular by reference to an identifier such as a name, an identification
number, location data, an online identifier or to one or more factors specific
to the physical, physiological, genetic, mental, economic, cultural or social identity
of that natural person.
means any operation or set of operations which is performed on Personal Data or
on sets of Personal Data, whether or not by automated means, such as
collection, recording, organization, structuring, storage, adaptation or
alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination,
restriction, erasure or destruction.
participation in the Privacy Shield applies to the Personal Data subject to EU and
Swiss data protection law that (i) Panorays receives from Panorays Ltd. and/or
(ii) Panorays collects and/or Processes on behalf of Panorays Ltd.
an identity driven protection platform helps the modern enterprise secure their
hybrid IT systems (the “Service”).
In order to perform the
Service, we, Panorays,
Inc. may use Personal Information, namely, for the purpose of usability of the
SaaS platform and to contact Customers to provide our services. Also, for the
purpose of Marketing and customer database for contact information.
Panorays will Process the Personal Data it receives as
described in Section 2, for the purposes of usability of the SaaS platform and to contact Customers
to provide our services. To
fulfill these purposes, We may, without limitation, use the Personal Data to
contact data subjects, to discuss or execute contracts, to provide the Service,
to provide support and maintenance, to correct and address technical or service
problems, for marketing purposes, to comply with applicable laws, regulations
and orders from public authorities or courts and/or for the establishment,
exercise or defense of legal claims, whether in court proceedings or in an
administrative or out-of- court procedures.
Subject to Section 6 below, We will not transfer Personal Data
originating in the EU and/or Switzerland to third parties unless such third parties have entered into an agreement in writing with
us requiring them to provide at least the same level of protection to the
Personal Data as required by the Principles of the EU-U.S. Privacy Shield
Framework and the Swiss-U.S. Privacy Shield Framework. We may transfer Personal Data to
processors, service providers, vendors, contractors, partners and agents
(collectively “Processors”) who need the information in order to
provide services to or perform activities on Our behalf. In cases of onward
transfer to third parties of Personal Data received pursuant to the EU-U.S.
Privacy Shield and the Swiss-U.S. Privacy Shield, Panorays is
The abovementioned Processors and the
description of the services that they provide and/or the activities that they
perform are set out in the table below:
Data subjects have the right to access Personal
Data about them, and in some cases to limit use and disclosure of their
Personal Data. If you would like to request access to the Personal Data or to
limit use and disclosure of your Personal Data we have processed on behalf of
one of the Customers, please contact: [email protected] and provide your name, contact information and
observe the required formalities under applicable law.
Panorays may be required in certain
circumstances to disclose Personal Data in response to lawful requests by courts
or public authorities, including to meet national security or law enforcement
In compliance with the Privacy Shield
Principles, Panorays commits to resolve complaints about Our collection or use
of your Personal Data. EU and Swiss individuals with inquiries or complaints
regarding Our Privacy Shield policy should first contact Panorays at: [email protected]
or by postal mail sent to:
Panorays, Inc. Attn: Privacy Shield Inquiry(HLTH LLC / Panorays)155 East 44th Street, Suite 701, New York, NY 10017USA
Panorays has further committed to refer
unresolved privacy complaints under the EU-U.S. Privacy Shield Principles
and the Swiss-U.S. Privacy Shield Principles
to JAMS, a non-profit alternative dispute resolution provider located in
the United States to assist with the complaint resolution process. If you do
not receive timely acknowledgment of your complaint, or if your complaint is
not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for
more information and to file a complaint. The services of JAMS are provided at
no cost to you.
Panorays is subject to the investigatory and
enforcement powers of the Federal Trade Commission (FTC) to ensure
compliance with the EU-US Privacy Shield Principles and the Swiss-U.S. Privacy
Shield Principles outlined in this
Under certain conditions, more fully described
on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you
may also be able to invoke binding arbitration when other dispute resolution
procedures have been exhausted.