Last Updated: Jan 01, 2024

Polish Pages is a business directory service and affiliated news and classified service provided by Polish Pages, Inc., a New York Corporation (“we,” “us,” “our,” etc. “Polish Pages” or “Company”).  We are not certified under the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield”), due to non-recognition of these programs in the EU.  Nonetheless, we are committed to the privacy principles embodied in the Privacy Shield programs.  We are providing this separate statement to explain how Polish Pages adheres to the Privacy Shield Principles including the Supplemental Principles, (collectively, the “Privacy Shield Principles”) for Personal Data received from entities in the European Economic Area (the “EEA”), the United Kingdom (“UK”) and Switzerland.

This Polish Pages Privacy Shield Statement and our Company Privacy Policy describe the privacy practices that we implement for Personal Data received from the EEA, UK or Switzerland consistent with Privacy Shield. This Privacy Shield Statement uses terms that are defined in the Privacy Policy.

If there is any conflict between the terms in this Privacy Shield Statement and the Privacy Shield Principles as concerns the Personal Data received under the Privacy Shield, the Privacy Shield Statement shall govern to the extent of the conflict. To learn more about the Privacy Shield program visit www.privacyshield.gov.

Privacy Shield Principles

Notice and Choice (Principles 1 & 2)

Our Privacy Policy describes how we use Personal Data we receive from different sources. This Privacy Shield Statement describes how we process Personal Data covered by the Privacy Shield.

If you are a Client, Polish Pages may act as an agent for you in relation to the Personal Data that you provide or make available to Polish Pages. We usually will not have a relationship with your Customers. Our Clients are responsible for ensuring that Customers are provided with appropriate notice and choice with respect to their Personal Data.

To the extent recommended by the Privacy Shield Principles, Polish Pages will seek opt-in consent for certain uses and disclosures of sensitive data. Individuals in the EU, UK and Switzerland (together: “EU/UK/CH Customers”) may contact Polish Pages as indicated below regarding Polish Pages’ use or disclosure of their Personal Data. Unless otherwise consented by EU/UK/CH Customers, Polish Pages uses Personal Data only for purposes that are materially the same as those indicated in this Policy.

Data Integrity and Purpose Limitation  (Principle 3)

We only collect Personal Data that is relevant to providing our Services or as provided by our Clients. We process Personal Data compatible with us providing the Services or as otherwise notified to you. We take reasonable steps to ensure that the Personal Data received under the Privacy Shield is needed for Polish Pages’ Services, accurate, complete, and current.

Accountability for Onward Transfers (Principle 4)

This Privacy Shield Statement and our Privacy Policy describe how Polish Pages shares Personal Data.

Except as permitted or required by applicable law and in accordance with Polish Pages’ role as a processor, Polish Pages generally does not share Personal Data of EU/UK/CH Customers with third-party controllers. In the event Polish Pages transfers or discloses Personal Data of EU/UK/CH Customers to a third-party data controller outside of the EU, UK, or Switzerland, Polish Pages would require such controller to agree to (a) only process the Personal Data for purposes consistent with consent provided by the relevant EU/UK/CH Customer; (b) provide the same level of protection for Personal Data as recommended by the Privacy Shield Principles; and (c) notify Polish Pages and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data consistent with the Privacy Shield Principles.

Polish Pages may disclose Personal Data to trusted third parties as indicated in its Privacy Policy, or to its Client data controllers that have a direct relationship to the EU/UK/CH Customer without offering an opportunity to opt out (for example, if a Polish Pages Client places a business directory listing or advertisement and you click on such listing or advertisement on the Website, Polish Pages may provide such click data to its Client).  Polish Pages requires that its agents and service providers that have access to Personal Data within the scope of this Privacy Shield Statement provide the same level of protection indicated in the Privacy Shield Principles. We ensure that our agents process Personal Data in a manner consistent with the Privacy Shield Principles, unless we have a good faith basis to find that we are not responsible for any incident or data breach giving rise to damage.

We may also need to disclose Personal Data in response to lawful requests by public authorities, for law enforcement or national security reasons, or when such action is necessary to comply with a judicial proceeding or court order, or when otherwise required by law. We do not offer an opportunity to opt out from this category of disclosure.

Data Security (Principle 5)

We use reasonable and appropriate physical, electronic, and administrative safeguards to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data and the risks involved in processing that information.  In particular, we store data on in house servers over which we have control, and minimize our use of third party cloud storage.  We use Microsoft as a third party cloud storage vendor and upon good faith inquiry we understand that Microsoft provides security consistent with the Privacy Shield Principles and general principles of data privacy and protection.

Access to Personal Data (Principle 6)

Our Privacy Policy explains how you may access and/or submit requests to review, correct, update, suppress, or delete Personal Data. You can ask to review and correct Personal Data that we maintain about you by sending a written request to privacy@poland.us. We may limit or deny access to Personal Data where providing such access is unreasonably burdensome, expensive under the circumstances, or as otherwise permitted by the Privacy Shield Principles.  In general, such requests will be more easily and efficiently responded to by the Polish Pages Client with whom a data subject has a direct relationship (i.e. the Client who places a business listing or advertisement with Polish Pages which a Customer clicks on).

If in a given instance Polish Pages is authorized and instructed to act on behalf of its Client, Polish Pages may assist a Client in responding to EU/UK/CH Customers exercising rights under the Privacy Shield Principles.

If you are a Customer of a Client, please contact the Client directly with your request to access or limit the use or disclosure of your Personal Data. If you contact us with the name of the Client to which you provided your Personal Data, we will refer your request to that Client and as appropriate or required support them in responding to your access request.

Recourse, Enforcement and Dispute Resolution (Principle 7)

If you have any questions or concerns, please write to us at the address listed below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with the Privacy Shield Principles.

Contact Information

If you have any questions regarding this Privacy Shield Statement, please contact us by email at privacy@poland.us, or please write to the following address:

Polish Pages, Inc.
Att: Polish Pages Legal
442 5th Avenue, #1600
New York, NY 10018
USA

Changes to this Privacy Shield Statement

We may change this Privacy Shield Statement from time to time, in accordance with the process described in our Privacy Policy. You can determine the revision date of this Privacy Shield Statement by referring to the “LAST UPDATED” date at the top of this Statement.