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This Privacy Policy Supplement (“Policy”) describes how Fellowes, Inc. and its subsidiaries and affiliates in the United States (“US”) (“Fellowes”, “we”, or “us”) collect, use, and disclose certain personally identifiable information that we receive in the US from the European Union and Switzerland (“European Personal Data”). This Policy applies to the following US affiliated entities: Fellowes Trading Company, Fellowes Brands, and ESI Ergonomic Solutions. 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.
Fellowes recognizes that the EU and Switzerland have established strict protections regarding the handling of European Personal Data, including requirements to provide adequate protection for European Personal Data transferred outside of the EU. To provide adequate protection for certain European Personal Data about consumers, corporate customers, job applicants and employees received in the US, Fellowes has elected to self-certify to the EU-US and Swiss-US Privacy Shield Framework administered by the US Department of Commerce (“Privacy Shield”). Fellowes complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce at https://www.privacyshield.gov.
For purposes of enforcing compliance with the Privacy Shield, Fellowes 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 Fellowes' 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.
Our Website Privacy Policy describes the categories of European Personal Data that we may receive in the US as well as the purposes for which we use that European Personal Data. Fellowes will only process European Personal Data in ways that are compatible with the purpose that Fellowes collected it for, or for purposes the individual later authorizes. Before we use your European 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. Fellowes maintains reasonable procedures to help ensure that European Personal Data is reliable for its intended use, accurate, complete, and current.
Third-Party Agents or Service Providers. We may transfer European 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 European 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 European Personal Data that we transfer to them.
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your European Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
Fellowes maintains reasonable and appropriate security measures to protect European Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
European Personal DataEuropean Personal Data.
Under the EU General Data Protection Regulations effective May 2018, EU residents have certain rights with respect to data collected by the Company. You may request copies of the data that we have collected relating to you, request that any inaccuracies be corrected, and request that such data be deleted. When you make such a request, we will balance your privacy rights with our legal obligations to preserve information.
Completed Data Request Forms should be sent to privacy@fellowes.com.
You can email any questions or complaints about the use or disclosure of your European Personal Data to us at privacy@fellowes.com. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your European Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with International Center for Dispute Resolution/AAA. If you are unsatisfied with the resolution of your complaint, you may contact ICDR/AAA at https://www.icdr.org/ for further information and assistance.
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 Fellowes 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).
If you have any questions about this Policy or would like to request access to your European Personal Data, please email us as follows: privacy@fellowes.com.
We reserve the right to amend this Policy from time to time consistent with the Privacy Shield's requirements.
Effective Date: September 30, 2016
Last modified: November 28, 2017