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Logikcull EU Resident Privacy Notice

Effective November 27th, 2019

This privacy notice is applicable to residents of the European Economic Area or where EU data protection laws, including, without limitation, the EU General Data Protection Regulation 2016/679 (“GDPR”), otherwise provides ("consumers" or "you"), who access the logikcull.com web site or the Logikcull service application ("Services") available at app.logikcull.com/login (collectively, "Sites"). This privacy notice supplements and is in addition to the information contained in Logik Systems, Inc.’s (collectively, "Logikcull", "we", "us", or "our") Privacy Policy located at https://www.logikcull.com/privacy-policy (“Logikcull Privacy Policy”).

This privacy notice does not apply to any third party applications or software that integrate with the Services through the Logikcull platform ("Third Party Services"), or any other third party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services and Sites ("Terms of Service"), including the processing of any data, files or other content submitted through customer's or its user's use of the Service accounts (collectively, "Hosted Data"). Each customer entering into the Terms of Service controls their instance of the Services and any associated Hosted Data. If you have any questions about specific setting and privacy practices, please contact:

Logik Systems, Inc.
Email: privacy@logikcull.com

INTERNATIONAL DATA TRANSFERS - PRIVACY SHIELD AND GDPR

Data protection law in certain jurisdictions differentiates between the "controller" and "processor" of information. In general, you are the controller of Hosted Data and Logikcull is the processor of Hosted Data and controller of Service Data.

Logikcull uses several safeguards if Logikcull transfers Information originating from the European Union, the European Economic Area and their member states, Switzerland and the United Kingdom to other countries not deemed adequate under applicable data protection law:

Privacy Shield: Logikcull is committed to participate in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. In cases of onward transfers of data, received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield, Logikcull is potentially liable.

To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce's Privacy Shield List. [https://www.privacyshield.gov/list].

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Logikcull is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.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 https://feedback-form.truste.com/watchdog/request.

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

Any issues with respect to data originating from the European Union, the European Economic Area and their member states, Switzerland and the United Kingdom to other countries notice may be sent to:

privacy@logikcull.com
Logik Systems, Inc.
℅ VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland

GDPR: Logikcull is also committed to complying with the General Data Protection Regulation when dealing with personal data from the European Union, the European Economic Area and their member states, Switzerland and the United Kingdom. Effective May 25, 2018, you may have certain statutory rights in relation to your personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services, on the Site, or as outlined in this Privacy Policy. To the extent that Logikcull's processing of your Hosted Data is subject to the GDPR, Logikcull relies on its legitimate interests, described above, to process your data. Logikcull may also process Service Data that constitutes your personal data for direct marketing purposes and you have a right to object to Logikcull's use of your personal data for this purpose at any time.

EU RESIDENT RIGHT TO ACCESS

EU RESIDENT RIGHT TO DATA RETENTION

Logikcull retains Hosted Data in accordance with your instructions as defined in applicable terms in the Terms of Service or, where applicable, other services agreements, or as otherwise required by applicable law.

Logikcull may retain your Service Data for as long as your account is active or as needed to provide you Services, comply with Logikcull's legal obligations, resolve disputes, and enforce agreements, and thereafter, Logikcull shall destroy or delete such Service Data within 18 months, unless otherwise required for business purposes. Notwithstanding the foregoing, Logikcull may keep any data after the periods set forth in this section to the extent such data is anonymized or as necessary for business purposes. If you have any questions about the retention of your personal data, you can contact Logikcull at privacy@logikcull.com .

EU RESIDENT COOKIE USE

The cookies described in Logikcull’s Privacy Policy will not collect personal data that is subject to the protections under the GDPR when dealing with personal data from the European Union, the European Economic Area and their member states, Switzerland and you can prevent your browser from accepting new cookies, have the browser notify you when you receive a new cookie, or disable. With respect to the Site, certain cookies are necessary for Logikcull to operate and disabling any such cookies may result in the inability to use or access the Site or Services. If cookies are disabled you may not be able to take advantage of some of the site features.

https://www.logikcull.com/privacy-policy

We have not relisted the categories of information collected/used/shared. We should discuss whether Logikcull wants three separate policies that stand-alone or supplemented.