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Privacy Shield Policy

Privacy Shield Policy Effective Date: January 1, 2020 | Last modified: January 7, 2020


This privacy shield policy ("Policy") describes how VS Media, Inc. and its subsidiaries and affiliates in the United States ("US") ("Company," "we," or "us") collect, use, and disclose certain personally identifiable information that we receive in the US from the European Economic Area ("EEA"), the United Kingdom ("UK"), and Switzerland ("Personal Data"). This Policy applies to the following US affiliated entities: VS Media, Inc. and HC Multimedia, LLC. This Policy supplements our Website Privacy Policy, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website Privacy Policy.

The Company recognizes that the EEA, the UK, and Switzerland have established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EEA, the UK, and Switzerland. To provide adequate protection for certain Personal Data about consumers, corporate customers, clients, suppliers, and business partners received in the US from the EEA, the UK, and Switzerland, the Company has elected to self-certify to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework administered by the US Department of Commerce ("Privacy Shield"). The Company adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.

For purposes of enforcing compliance with the Privacy Shield, the Company is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov. To review VS Media’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: https://www.privacyshield.gov/list.

Personal Data Collection and Use

Our Website Privacy Policy can be retrieved at the bottom of the home page and it describes the categories of Personal Data that we may receive in the US as well as the purposes for which we use that Personal Data. An example of this policy can be found here: https://www.sarajaycams.com/privacy.php The Company will only process Personal Data in ways that are compatible with the purpose that it was collected for, or for purposes the individual later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. The Company maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.

Data Transfers to Third Parties

Third-Party Agents or Service Providers. We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf as described in our Website Privacy Policy. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.

Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security

The Company maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

Access Rights

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the 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 someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

Questions or Complaints

You can direct any questions or complaints about the use or disclosure of your Personal Data to us at legal@vsmedia.com or +1 818-880-9021. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with JAMS, an independent dispute resolution provider located in the United States. If you are unsatisfied with the resolution of your complaint or if you do not receive timely acknowledgment of your complaint from us, you may contact JAMS at https://www.jamsadr.com/eu-us-privacy-shield for further information and assistance or to file a complaint. The services of JAMS are provided at no cost to you.

Binding Arbitration. You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with VS Media and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).

Contact Us

If you have any questions about this Policy or would like to request access to your Personal Data, please contact us as follows:

VS Media, Inc.
Chief Privacy Officer
4607 Lakeview Canyon Rd. #338
Westlake Village, CA 91361
1-800-685-9236 (USA Only)
1-818-880-9021 (Outside USA)
legal@vsmedia.com
Oct. 11
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