Karl Yost Photography may receive
Personal Data from its own personnel as well as from its affiliates
and other
parties located in the EU/EEA. Such information may contain names,
addresses,
email addresses and payment information and may be about customers,
clients of
customers, business partners, consultants, employees, and candidates
for
employment and includes information recorded on various media as well
as
electronic data.
Other than its own human
resources data, Karl Yost Photography generally does not collect
Personal Data directly from individuals.
Karl Yost Photography, however, acting as a data processor may receive
Personal Data
via its customers.
Personal Data Collection
Principles:
- We shall inform an individual of the purpose for
which we collect and use their Personal Data and the types of third
parties to
which our Company discloses or may disclose that Personal Data. Our
Company
shall provide the individual with the choice and means for limiting
the use and
disclosure of their Personal Data. Notice will be provided in clear
and
conspicuous language when individuals are first asked to provide
Personal Data
to our Company, or as soon as practicable thereafter, and in any
event before
our Company uses or discloses the Personal Data for a purpose other
than for which
it was originally collected. Karl Yost Photography may be required
to disclose
Personal Data in response to lawful request by public authorities,
including to
meet national security or law enforcement requirements.
- Individuals have the opportunity to choose (opt
out) whether their Personal Data is (1) to be disclosed to a
non-Agent third
party or (2) to be used for a purpose other than the purpose for
which it was
originally collected or subsequently authorized by the individual by
contacting
our privacy officer via email at privacy@kyostphoto.com.
Agents, technology vendors and/or contractors
of Karl Yost Photography or its affiliates may have access to
an individual’s
Personal Data on a need to know basis for the purpose of performing
services on
behalf of Karl Yost Photography or providing or enabling elements of
the services.
All such agents, technology vendors and contractors who have access
to such
information are contractually required to keep the information
confidential and
not use it for any other purpose than to carry out the services they
are
performing or as otherwise required by law.
-
Accountability
for Onward Transfer. Prior to disclosing Personal Data to a
third party, we shall notify the
individual of such disclosure and allow the individual the choice
(opt out) of
such disclosure. We will:
- Limit the data we share with our partners and
vendors to only that data we have permission to share.
- Proactively confirm that our partners and
vendors understand purpose limitations.
- Ensure partners and vendors will make at least
the same level of privacy protection as required by the Privacy
Shield
principles to comply with the purpose limitation and appropriate
protection of
that data.
- Transfer such data only for limited and
specified purposes as detailed in the privacy policy.
- Ascertain that the agent is obligated to provide
at least the same level of privacy protection as is required by
the Principles.
- Take reasonable and appropriate steps to ensure
that the agent effectively processes the personal information
transferred in a
manner consistent with our organization’s obligations under the
Principles.
- Upon notice, take reasonable and appropriate
steps to stop and remediate unauthorized processing.
- Karl Yost Photography requires any third party agent
to notify us in the event that it makes a determination that it
can not longer
meet its obligation to provide the same level of protection as is
required by
the Privacy Shield principals.
- Provide a summary or representative copy, of the
relevant privacy policy provision of its contract with that agent,
to the
department upon request.
- Unless we prove that we are not responsible for
the event giving rise to the damage. Karl Yost Photography
recognizes its responsibility and potential liability for onward
transfers.
- Data
Security. We shall take reasonable steps to protect the
Personal Data from loss, misuse and unauthorized access,
disclosure, alteration and destruction. Our
Company has put in place appropriate physical, electronic and
managerial
procedures to safeguard and secure the Personal Data from loss,
misuse,
unauthorized access or disclosure, alteration or destruction.
However, our
Company cannot guarantee the security of Personal Data on or
transmitted via
the Internet.
- Data
Integrity and
Purpose Limitation. We shall only process Personal Data in a
way
that is compatible with and relevant for the purpose for which it
was collected
or authorized by the individual. To the extent necessary for those
purposes,
our Company shall take reasonable steps to ensure that Personal Data
is
accurate, complete, current and reliable for its intended use.
- Access
and Recourse. We acknowledge the individual’s right to access
their Personal Data. We shall allow an individual access to their
Personal Data and
allow the individual the opportunity to correct, amend or delete
inaccurate
information, except where the burden or expense of providing access
would be
disproportionate to the risks to the privacy of the individual in
the case in
question or where the rights of persons other than the individual
would be
violated. Individuals may contact our Privacy Officer via email to
request
access.
- Enforcement
and Liability. The Federal Trade Commission has jurisdiction
over Karl Yost Photography compliance with the Privacy Shield. In
compliance with the
EU-US Privacy Shield Principles, Karl Yost Photography commits to
resolve complaints
about privacy and our collection or use of Personal Data. European
Union or
Swiss individuals with inquiries or complaints regarding this
privacy policy
should first contact us at:
Karl Yost Photography, LLC
PO Box 651
Yellow Springs, OH 45387 USA
privacy@kyostphoto.com
-
A.
Human
Resources Data. Karl Yost Photography would generally not
collect human resources
data. If there was reason to collect
such information and there was a complaint it would be addressed
within a
timely period. If your complaint is not
satisfactorily addressed by Karl Yost Photography, and your inquiry
or complaint
involves human resource data, you may have your complaint considered
by an
independent recourse mechanism: for EU/EEA Data Subjects, a panel
established
by the EU data protection authorities (“DPA Panel”), and for Swiss
Data
Subjects, the Swiss Federal Data Protection and Information
Commissioner
(“FDPIC”). To do so, you should contact the state or national data
protection
or labor authority in the jurisdiction where you work. Karl
Yost Photography agrees to cooperate with the
relevant national DPAs and to comply with the decisions of the DPA
Panel and
the FDPIC. The services of EU DPAs are provided at no cost to
you.
-
B.
Independent
Recourse - Non-Human Resources Data. Karl Yost Photography has
further committed to refer
unresolved Privacy Shield complaints to EU data protection
authorities (“DPA Panel”) and The Swiss Federal Data
Protection and
Information Commissioner (“FDPIC”), an alternative dispute
resolution provider
located in the (the
EU, or Switzerland, as applicable). If you do not
receive timely acknowledgment of your complaint from us, or if we
have not
resolved your complaint, please contact or visit:
EU DPA Contact:
https://ec.europa.eu/info/departments/justice-and-consumers_en#contact
Phone number+32 2 299 11 11 (Commission switchboard)
Postal address:
Directorate-General for Justice and Consumers
European Commission
1049 Bruxelles/Brussel Belgium
FDPIC Contact:
https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection---swi
tzerland.html
Data Protection and Information Commissioner of Switzerland
Tell. +41 58 462 43 95; Fax +41 58 462 99 96
Please note that if your complaint is not resolved through
any of the above channels, under limited circumstances, a binding arbitration
option may be available before a Privacy Shield Panel
- C. Amendments.
This Privacy Statement may be
amended from time to time consistent with the requirements of the
Shield
Frameworks. We will post any revised policy on this website.
- D. Information Subject to Other Policies .
We are committed to following
the Principles for all Personal Data within the scope of the Privacy
Shield
Frameworks. We are committed to following the Principles for all
Personal Data
within the scope of the Privacy Shield Frameworks. However, certain
information
is subject to policies of Karl Yost Photography that may differ in
some respects from
the general policies set forth in this Privacy Statement. Updated:
June 3, 2019.
Updated: September 26, 2020