Notice of Certification under EU-U.S. Privacy Shield Framework

PostUp Digital LLC PostUp Digital LLC (also doing business as UnsubCentral) (“PostUp,” “us,” “we,” “our”) complies with the EU-U.S. Privacy Shield Framework (the “Privacy Shield”) set forth by the U.S. Department of Commerce and the European Commission to govern transfers of personal data from the European Union (EU) to the United States. PostUp commits to all Privacy Shield Principles with respect to all such data collected and processed by PostUp. For additional information regarding the Privacy Shield program, including PostUp’s certification under the framework, please visit https://www.privacyshield.gov. A list of organizations that are certified under the Privacy Shield can be found at https://www.privacyshield.gov/list.

With respect to personal data of subjects located in Switzerland, PostUp continues to adhere to the U.S.‑Swiss Safe Harbor Framework and its principles (the “Safe Harbor”). Additional information about the Safe Harbor can be found at http://2016.export.gov/safeharbor/swiss/.

In addition to the terms and disclosures set forth in PostUp’s Privacy Policy, the following terms and disclosures apply to personal data collected from subjects of the EU under the Privacy Shield and, where indicated, to subjects of Switzerland under the Safe Harbor:

Data Collected and Received

PostUp may collect or maintain the following personal data from clients or prospective clients, which is typically business contact information:

  • First and Last Name
  • Street or mailing address, city, state, and zip code
  • E-mail Address
  • Occupation/title
  • Company
  • Phone number
  • Company URL
  • Business type
  • Information volunteered by customers, such as survey information
  • Any other PII the customer submits during the course of normal correspondence with PostUp or its third-party partners

In addition, PostUp may collect certain aggregate and non-personal data from our customers, including standard computer information that a user’s browser sends to every website you visit, such as the IP address, browser type and language, cookie information, access times, referring website addresses and requested website pages.

Data Uses

PostUp collects and processes data for the purpose of providing online services to customers. For example, PostUp uses the personal data it collects from users in order to answer questions and resolve issues; to provide users with access to our website and to monitor use of the site; to provide users with product information and support services; to notify users of technical updates or changes in policy; to improve the content and functionality of our website and the products and services we offer; to help us better understand our customers and their preferences; and to deliver or offer additional services. We may also use personal data to contact our corporate customers for marketing purposes if they elect to continue to receive such communications.

Data Shared with or Disclosed to Third Parties

Under certain circumstances, PostUp may share personal data we collect with certain third parties without further notice to the user in connection with third-party applications and services that interoperate with the Site or the Service; business transfers (e.g., in the event of a corporate sale, merger, reorganization, dissolution, or similar event); the outsourcing of certain business-related functions to agents, consultants, and related third parties; and legal requirements and other circumstances under which PostUp is compelled or otherwise required to disclose such personal data.

Liability for Onward Transfers

If a third party processes the personal data of an EU subject on behalf of PostUp in a manner inconsistent with the Privacy Shield Principles, PostUp may face liability with respect to any damage suffered by that subject unless PostUp can prove that it is not responsible for the event giving rise to such damage.

Choices and Means to Access and Limit Use and Disclosure of Personal Data

EU and Swiss residents have the right to access personal data about them and to request the correction, amendment, removal, or limitation of the use and disclosure of their personal data collected and processed by PostUp. All such requests should be sent by e-mail to privacy@postup.com or by regular mail to:

PostUp Digital LLC

Attn: Privacy Officer
3305 Steck Avenue, Suite 300
Austin, Texas 78757

Dispute Resolution and Arbitration

If you reside within the EU or Switzerland, any inquiries or complaints regarding PostUp’s compliance with the Privacy Shield or Safe Harbor should be sent to the PostUp e-mail or postal address set forth above. PostUp will respond within 45 days of receiving such inquiry or complaint.

If you are not completely satisfied with the resolution of your information privacy concern in working with PostUp directly, you may contact our dispute resolution provider, the Direct Marketing Association (DMA), for assistance in resolving your Privacy Shield or Safe Harbor information privacy complaint. For more information regarding the DMA’s complaint handling procedures, please visit https://thedma.org/resources/compliance-resources/privacy-shield-safe-harbor-guide/.

You may submit a complaint to the DMA in connection with the Privacy Shield or the Safe Harbor via the following link, as applicable, or to the mailing address set forth below:

Privacy Shield: https://thedma.org/shield-complaint-form/

Safe Harbor: https://thedma.org/resources/consumer-resources/eu-u-s-privacy-shield-u-s-swiss-safe-harbor-program-for-consumers/the-dma-safe-harbor-program-consumer-complaint-form/

DMA
Privacy Shield/Safe Harbor Line
1333 Broadway, Suite 301
New York, NY 10018

Under certain conditions, individuals located in the EU may be able to invoke binding arbitration before the Privacy Shield Panel jointly created by the U.S. Department of Commerce and the European Commission.

Federal Trade Commission Enforcement

PostUp is subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to its compliance with the Privacy Shield.

Dosclosure Requests by Public Authorities

PostUp may be required to disclose your personal data in response to a lawful request by public authorities, including to meet national security or law enforcement needs.

Effective Date: September 29, 2016