Privacy Shield Commitments

RaGaPa 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 (collectively, the “Privacy Shield”). RaGaPa has certified to the Department of Commerce that it adheres to the “Privacy Shield Principles.” If there is any conflict between the terms in our 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/.

RaGaPa is responsible for the processing of personal information it receives under the Privacy Shield framework and subsequently transfers to a third party acting as an agent on our behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. 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 and our Privacy Policy require and limiting their use of the data to the specified services provided on our behalf.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

Our Privacy Policy describes the categories of European personal information that we may receive in the US as well as the purposes for which we use that European personal information.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at Jams Adr.

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.

If you are a resident of a European Union member state or Switzerland, you also have the right to seek assistance from the data protection authorities, Click here for EU Data Protection Authorities and click here for Swiss Federal Data Protection and Information Commissioner.