My Docs Online Privacy Shield Policy and GDPR Compliance

My Docs Online (My Docs Online, Inc.) complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.   My Docs Online has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

For purposes of this policy:

“End user” means any person located in the EU or Switzerland who is a user of My Docs Online’s products or services or whose Personal Data may be stored by an end user using My Docs Online’s products or services.

“End user” also includes any individual or entity that registers for or purchases My Docs Online’s products or services.

“Personal Data” means any information that is transferred to My Docs Online in the U.S. from the EU or Switzerland, is stored, relates to an identified or identifiable end user, and can be linked to that individual.

“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings.

“GDPR” refers to the European Union’s General Data Protection Regulation, effective as of 25 May 2018

How My Docs Online Obtains Personal Data

My Docs Online provides Internet-based data storage and transfer resources. In connection with the registration and payment processes for My Docs Online’s products and services, My Docs Online obtains Personal Data about customers.

My Docs Online also collects Personal Data from end users when an end user visits My Docs Online’s website at https://mydocsonline.com (the “Site”) and provides Personal Data to My Docs Online on or through the Site. In addition, My Docs Online obtains Personal Data, such as contact information, in connection with maintaining its end user relationships and providing products and services to its Customers.

In connection with providing its products and services on behalf of its Customers, My Docs Online may access or obtain certain end user Personal Data for storage, backup, maintenance, marketing, general communications and administration purposes. In connection with these offerings, My Docs Online acts as a service provider to its Customers and pursuant to their instructions.

My Docs Online’s practices regarding the collection, storage, use, transfer and other processing of Personal Data comply, as appropriate, with the Privacy Shield principles of notice, choice, onward transfer, access, security, data integrity, and enforcement and oversight.

Notice

My Docs Online provides information in its Online Privacy Policy available at https://mydocsonline.com/privacy/ regarding its practices related to Personal Data collected on the Site, including the purposes for which My Docs Online collects and uses end user Personal Data it collects on the Site. In circumstances in which My Docs Online acts as a service provider for its Customers, My Docs Online’s Customers are responsible for providing appropriate notice to their end users whose Personal Data are transferred to the U.S. and obtaining any requisite consent.

Choice

In circumstances in which My Docs Online collects Personal Data directly from end users, it offers end users the opportunity to choose whether My Docs Online may use their Personal Data for a purpose that is incompatible with the purpose for which the information was originally collected or subsequently authorized by the individual. End users may contact My Docs Online as indicated below regarding the company’s use or disclosure of their Personal Data.

In circumstances in which My Docs Online maintains Personal Data about end users with whom My Docs Online does not have a direct relationship because My Docs Online obtained or maintains the end users’ data as a service provider for its Customers, My Docs Online’s Customers are responsible for providing the relevant individuals with certain choices with respect to the Customers’ use or disclosure of the individual’s Personal Data.

My Docs Online may disclose Personal Data without offering an opportunity to opt out if it is required to do so by law or legal process, to law enforcement or other government authorities, or when My Docs Online believes disclosure is necessary to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity. My Docs Online also reserves the right to transfer Personal Data in the event it sells or transfers all or a portion of its business or assets (including in the event of a reorganization, dissolution or liquidation). Should such a sale or transfer occur, My Docs Online will use reasonable efforts to direct the transferee to use the Personal Data in a manner that is consistent with My Docs Online’s privacy policies. My Docs Online uses Personal Data only for the purposes indicated in this Policy or the Online Privacy Policy unless it has a legal basis, such as consent, to use it for other purposes. To the extent required by law, My Docs Online obtains prior opt-in consent at the time of collection for the processing of Personal Data for marketing purposes and Sensitive Data, to the extent that My Docs Online collects any Sensitive Data.

Accountability for Onward Transfer

My Docs Online does not currently share end user data with third parties. In the future event that My Docs Online shares end user data with third parties My Docs Online will require third parties to whom it discloses Personal Data to agree to provide at least the same level of protection for Personal Data as is required by the relevant Privacy Shield principles, except as permitted or required by applicable law.

Access

Where appropriate, My Docs Online provides end users with reasonable access to the Personal Data My Docs Online maintains about them. My Docs Online also provides a reasonable opportunity for end users to correct, amend or delete that information where it is inaccurate, as appropriate. My Docs Online may limit or deny access to Personal Data where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Privacy Shield principles. The right to access personal information also may be limited in some circumstances by local law requirements. End users may request access to their Personal Data by contacting My Docs Online as indicated below. We will respond to all access requests within 30 days.

In circumstances in which My Docs Online maintains Personal Data about end users with whom My Docs Online does not have a direct relationship because My Docs Online obtained or maintains the end users’ data as a service provider for its Customers, My Docs Online’s Customers are responsible for providing end users with access to the Personal Data and the right to correct, amend or delete the information where it is inaccurate. In these circumstances, end users should direct their questions to the appropriate My Docs Online Customer. When an end user is unable to contact the appropriate Customer, or does not obtain a response from the Customer My Docs Online will provide reasonable assistance in forwarding the individual’s request to the end user.

Security

My Docs Online takes reasonable precautions to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration, and destruction.

Data Integrity & Purpose Limitation

My Docs Online takes reasonable steps to ensure that the Personal Data the company processes are relevant for the purposes for which they are to be used, reliable for their intended use, and accurate, complete and current. In this regard, My Docs Online depends on its end users and Customers (with respect to Personal Data of end users with whom My Docs Online does not have a direct relationship) to update and correct Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized by the individuals. End users (and Customers, as appropriate) may contact My Docs Online as indicated below to request that My Docs Online update or correct relevant Personal Data.

Recourse, Enforcement and Liability

My Docs Online is responsible for the processing of personal data it receives, under the Privacy Shield Framework. My Docs Online complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred to the Privacy Shield Framework, My Docs Online is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, My Docs Online may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Privacy Shield

In compliance with the Privacy Shield Principles, My Docs Online commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact My Docs Online at: https://mydocsonline.com/contact/

My Docs Online has further committed to refer unresolved Privacy Shield complaints to JAMS (formerly known as Judicial Arbitration and Mediation Services, Inc.), an alternative dispute resolution provider located in the United States, Canada, and the United Kingdom. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com for more information or to file a complaint.  The services of JAMS are provided at no cost to you.

How to Contact My Docs Online

To contact My Docs Online refer to the options at https://mydocsonline.com/contact/