EFFECTIVE ON: JANUARY 19, 2015

GENERAL

ADA Platform Technology (“ADA Platform Technology” or “we”) recognize(s) that the European Community has established a data protection regime pursuant to Directive 95/46/EC (the “Directive”). The Directive applies to the European Economic Area (“EEA”). The Swiss Confederation (“Switzerland”) has also established a data protection regime pursuant to the Federal Act on Data Protection (“FADP”). These regimes restrict companies in the EEA and Switzerland (collectively, “EEA/CH”) from transferring personal data about individuals in the EEA/CH to the United States, unless there is “adequate protection” for such personal data when it is received in the United States. To create such “adequate protection” and to overcome the restriction on international data transfers established by the Directive and the FADP, we adhere to the Safe Harbor Privacy Principles published by US Department of Commerce (“Safe Harbor Principles”) with respect to certain personal data about individuals in the EEA/CH that we receive from our subsidiaries, customers, and other business partners. For more information on the Safe Harbor Principles, please visit http://www.export.gov/safeharbor.

SCOPE OF THIS NOTICE

This Notice addresses data subjects in the EEA/CH (“EEA/CH Persons”) whose data we may receive from one of our subsidiaries, customers, suppliers, or other business partners. This Notice does not apply to employees of ADA Platform Technology , or the data that we receive directly through ADA Platform Technology’s publicly accessible websites. In addition, our customers use our hosted technology platform to store and process data of their own customers at their own discretion. In this instance, we act only as a storage and service provider, without any interest or knowledge about what is being stored, and shall only access such data at our customer’s request in connection with customer support or account administration matters, or as may be required by law.

CATEGORIES OF EEA/CH DATA

ADA Platform Technology sells sales and marketing software-related services primarily to small businesses. Our customers use our hosted technology platforms to store and process EEA/CH Data at their own discretion. Since EEA/CH Data covered by this Notice is by definition sent to us by another company, the categories of data sent and the purposes of processing often depend on such other company, with whom the EEA/CH Persons typically have a closer employment or business relationship (and which, therefore, can provide additional information on categories of data shared with us).

PURPOSES

We collect and use EEA/CH Data for the purposes of providing products and services to our customers, communicating with corporate business partners about business matters, processing EEA/CH Data on behalf of corporate customers, providing information on our services, and conducting related tasks for legitimate business purposes.

DISCLOSURE

We share EEA/CH Data with our subsidiaries, agents, and contractors, who process EEA/CH Data on behalf of ADA Platform Technology . We also share EEA/CH Data with other third parties for the purposes for which we receive the EEA/CH Data (e.g., performance of contractual obligations and rights), and we may also disclose EEA/CH Data where we are legally required to disclose (e.g., under statutes, contracts or otherwise) or the disclosure is permitted by law or the Safe Harbor Principles, and we have a legitimate business interest in such disclosure.

With respect to marketing emails, EEA/CH Persons may opt out of receiving further email marketing communications from ADA Platform Technology by submitting the opt-out request form located at https://veps.online/Manage-Subscriptions or by clicking the “Unsubscribe” link found in the footer of our email messages. EEA/CH Persons may also send an email to dataoptout@veps.online to opt out of disclosures to third parties, but such a limitation on data sharing may make it difficult or impossible for us to provide the requested services.

DATA INTEGRITY & SECURITY

ADA Platform Technology employs technical, administrative, and physical measures that are reasonably designed to help protect personal information from loss, unauthorized access, disclosure, alteration, or destruction.

ACCESS & REVIEW

If you are an EEA/CH Person about whom we hold EEA/CH Data, you may request access to, and the opportunity to update, correct, or delete, such EEA/CH Data. To submit such requests or raise any other questions, please contact the business that provided your EEA/CH Data to us. You can also contact us at dataoptout@veps.online. We reserve the right to take appropriate steps to authenticate an applicant’s identity, to charge a reasonable fee before providing access and to deny requests, except as required by the Safe Harbor Principles.

SAFE HARBOR CONTACT & DISPUTE RESOLUTION PROCESS

If you have questions, please contact us at:
ADA Platform Technology
Attn: Legal Department
P. O. Box 130035
The Woodlands, Texas 77393
USA

Or you may call us at +1 800 212-2642. We will promptly investigate and attempt to resolve complaints and disputes in a manner that complies with the principles described in this Notice. If you are not satisfied with our response, or if contacting us does not resolve your complaint, you can contact VeraSafe™ here: https://www.verasafe.com/dispute-submission. VeraSafe has been appointed as our third-party dispute resolution provider for Safe Harbor disputes, and we have agreed to participate in the VeraSafe Safe Harbor Dispute Resolution Procedure.