SCOPE This Policy applies to all Blissful Elopements entities in the US that process Personal Data. “Consumer” “Consumer” means any natural person who is located in the EU. “Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data as referred to in Privacy Shield materials. “Employee” means any current, former or prospective employee, temporary worker, intern or other non-permanent employee of Blissful Elopements or any current or prospective subsidiary or affiliate of Blissful Elopements. “European Union (“EU”)” means and country located within the European Union. “Blissful Elopements entities (“Blissful Elopements”)” means Blissful Elopements and all affiliates or other entities owned or controlled by Blissful Elopements in the US, irrespective of their different denominations that such entities may hold in different jurisdictions in the US. “Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity and includes information, that (i) relates to an identified or identifiable Customer, Employee or Supplier’s representative; (ii) can be linked to that Customer, Employee or Supplier’s representative; (iii) is transferred to Blissful Elopements in the U.S. from the EU, and (iv) is recorded in any form. “Privacy Shield” means the EU-US Privacy Shield framework and agreement between the United States of America, via the US Department of Commerce and the EU relating to the protection of Personal Data. “Privacy Shield Policy” means the Blissful Elopements Privacy Shield Policy that further details the handling of EU persons Personal Data when transferred to or obtained by Blissful Elopements personnel in the USA; and such policy appears on the company global website www.Blissful Elopements.com , as well as on the company internet, and other applicable company websites, e.g. EU company office websites. “Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield. “Sensitive Personal Data” means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership or concerning health or sex, and 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. “Supplier” means any supplier, vendor or other third party located in the USA and/or the EU that provides services or products to Blissful Elopements. For the purposes of this Policy Suppliers shall be included within the definition of “Consumers” above. “Systems Privacy Point of Contact” means individual officers designated by Blissful Elopements as the initial points of contact for inquiries, complaints, or questions regarding privacy matters. Currently, such officers are identified at the end of this Policy. “Processing” is defined as any action that is performed on Personal Data, whether in whole or in part by automated means, such as collecting, modifying, using, disclosing, or deleting such data. This Policy does not cover data rendered anonymous or where pseudonyms are used. Data is rendered anonymous if individuals are no longer identifiable or are identifiable only with a disproportionately large expense in time, cost or labor. The use of pseudonyms involves the replacement of names or other identifiers with substitutes, so that identification of individual persons is either impossible or at least rendered considerably more difficult. If data rendered anonymous become no longer anonymous (i.e. individuals are again identifiable), or if pseudonyms are used and the pseudonyms allow identification of individual persons, then this Policy shall apply again.
APPLICATION OF LOCAL LAWS This Policy is designed to provide compliance with all relevant applicable laws in the EU and in particular those transposing the Directive. Blissful Elopements recognizes that certain laws might be modified to require stricter standards than those described in this Policy, in which case the stricter standards shall apply. Blissful Elopements will handle Personal Data in accordance with local law at the place where the Personal Data is processed. If applicable law provides for a lower level of protection of Personal Data than that established by this Policy, then this Policy shall prevail. Any questions about applicable legislation and Blissful Elopements’ compliance with it shall be addressed to Blissful Elopements’ local legal department or to the legal department in the US.
PRINCIPLES FOR PROCESSING PERSONAL DATA Blissful Elopements respects Consumer’s privacy and is committed to protecting Personal Data in compliance with the applicable legislation in the EU. This compliance is consistent with Blissful Elopements desire to keep its Employees and Consumers informed and to recognize and respect their privacy rights. Blissful Elopements will observe the following principles when processing Persona l Data:
Data will be processed fairly and in accordance with applicable law.
Data will be collected for specified, legitimate purposes and not processed further in ways incompatible with those purposes.
Data will be relevant to and not excessive for the purposes for which they are collected and used. For example data may be rendered anonymous if deemed reasonable, feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses.
Data subjects in the EU will be asked to provide their clear and unequivocal consent for the collection, processing and transfer of their Personal Data.
Data will be accurate and, where necessary kept up up-to-date. Reasonable steps will be taken to rectify or delete Personal Data that is inaccurate or incomplete.
Data will be kept only as it is necessary for the purposes for which it was collected and processed. Those purposes shall be described in this Policy.
Data will be deleted or amended following a relevant request by the concerned data subject, should such notice comply with the applicable legislation each time.
Data will be processed in accordance with the individual’s legal rights (as described in this Policy or as provided by law).
Appropriate technical, physical and organizational measures will be taken to prevent unauthorized access, unlawful processing and unauthorized or accidental loss, destruction or damage to data. In case of any such violation with respect to Personal Data, Blissful Elopements will take appropriate steps to end the violation and determine liabilities in accordance with applicable law and will cooperate with the competent authorities.
TYPES OF DATA PROCESSED As permitted by local laws, the Personal Data relating to Consumers may include:
Contact information, such as name, postal address, email address and telephone number; and
Personal Data in content Consumers provide on Blissful Elopements website and other data collected automatically through the website (such as IP addresses, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our website, and dates and times of website visits).
Financial account information.
Blissful Elopements also may obtain and use Consumer Personal Data in other ways for which Blissful Elopements provides specific notice at the time of collection (including but not limited to e.g. surveys, focus groups, market research, inbound and outbound Consumer communications and education, etc.).
WAYS OF OBTAINING PERSONAL DATA The ways by which Blissful Elopements obtains Personal Data are defined hereby. Blissful Elopements does not obtain any personal information about Consumers unless the Consumer has provided that information to Blissful Elopements in a way providing for its clear and unequivocal consent to do so including but not limited to visiting Blissful Elopements website, consent form, survey, or completion of an on-line or hard copy form. Consumers may choose to submit personal, private information by facsimile, regular mail, e-mail, or electronic transmission over our internal web site, postal delivery or personal delivery, as each of these methods may be deemed applicable each time.
PURPOSES FOR PERSONAL DATA PROCESSING Blissful Elopements processes personal data for legitimate purposes related to business and safety /security. The limitation of purposes shall be taken into consideration before any type of processing of Personal Data and shall not be subject to any changes without prior notification. For Consumer specific Personal Data, the purposes of processing may include:
Running day-to-day business relationship
Management of financial accounts
Business Development Activities
Conduct of transactions or facilitation of offering of Blissful Elopements services
Conduct of surveys, focus groups, market research, inbound and outbound Consumer communications and education
Processing Consumer requested services as outlined in signed contracts
For Client and Supplier specific information, the purposes of processing may include:
Management of its relationships with its Clients and Suppliers
Processing payments, expenses and reimbursements
Carrying out Blissful Elopements obligations under such contracts
If Blissful Elopements introduces a new process or application that will result in the processing of Personal Data for purposes that go beyond the purposes described above, Blissful Elopements will inform the concerned data subjects of such new process or application, new purpose for which the Personal Data are to be used, and the categories of recipients of the Personal Data.
SECURITY AND CONFIDENTIALITY Blissful Elopements is committed to taking appropriate technical, physical and organizational measures to protect Personal Data against unauthorized access, unlawful processing, accidental loss or damage and unauthorized destruction.
Equipment and Information Security To safeguard against unauthorized access to Personal Data by third parties outside Blissful Elopements, all electronic Personal Data held by Blissful Elopements are maintained on Systems that are protected by up-to-date secure network architectures that contain firewalls and intrusion detection devices. The data saved in servers is “backed up” (i.e. the data are recorded on separate media) to avoid the consequences of any inadvertent erasure, destruction or loss otherwise. The servers are stored in facilities with high security, access protected to unauthorized personnel, fire detection and response systems. The location of these servers is known only to a Blissful Elopements CEO.
Access security The importance of security for all personally identifiable information associated with Blissful Elopements Consumers is of highest concern. Blissful Elopements is committed to safeguarding the integrity of personal information and preventing unauthorized access to information maintained in Blissful Elopements databases. These measures are designed and intended to prevent corruption of data, block unknown and unauthorized access to our computerized system and information, and to provide reasonable protection of Personal Data in Blissful Elopements possession. All Consumer files are confidentially maintained in secured and locked file cabinets. Access to the computerized database is controlled by a log-in sequence and requires users to identify themselves and provide a password before access is granted. Users are limited to data required to perform their job function. Security features of our software and developed processes are used to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Training Blissful Elopements will be responsible for conducting adequate training sessions regarding the lawful, enumerated intended purposes of processing Personal Data, the need to protect and keep information accurate and up-to-date, the lawful purposes of collecting, handling and processing data that is transferred from the EU to the US and the need to maintain the confidentiality of the data to which employees have access. Authorized users will comply with this Policy and Blissful Elopements will take appropriate actions in accordance with applicable law, if Personal Data are accessed, processed, or used in any way that is inconsistent with the requirements of this Policy.
RIGHTS OF DATA SUBJECTS Any person has the right to be provided with information as to the nature of the Personal Data stored or processed about him or her by Blissful Elopements and may request deletion or amendments. All Consumers may request access to their own personal information and may correct or amend it as needed Consumers may contact the Privacy POC at Blissful Elopements to review, update, and revise their Personal Data. If access is denied, Consumer has the right to be informed about the reasons for denial. The person affected may resort to the dispute resolution outlined herein as well as in any competent regulatory body or authority. Blissful Elopements shall handle in a transparent and timely manner any type of internal dispute resolution procedure about Personal Data is conducted. If any information is inaccurate or incomplete, the person may request that the data be amended. If the person demonstrates that the purpose for which the data is being processed in no longer legal or appropriate, the data will be deleted, unless the applicable law requires otherwise.
TRANSFERS In connection with the activities described, Blissful Elopements may transmit Personal Data to: (i) Blissful Elopements headquarters in Chattanooga, TN, USA; moreover, Personal Data might be sent to the following third parties in or outside the EU:
Selected Third Parties: Blissful Elopements will not disclose or share any personal information with any external entity or third party, except to third party vendors and/or marketers upon Consumer’s explicit written consent.
Other Third Parties: Blissful Elopements may be required to disclose certain Personal Data to other third parties: (i) As a matter of law; (ii) to protect Blissful Elopements legal rights; (iii) in an emergency where the health or security of an employee is endangered (e.g. a fire); (iv) to Law Enforcement Authorities in accordance with local laws.
Blissful Elopements complies with all the Privacy Shield Principles of the Privacy Shield and has taken the necessary actions to register within the Privacy Shield framework. In this regard Blissful Elopements has adopted a Privacy Shield Policy, describing in detail the company’s compliance with Privacy Shield Principles for data transferred from the EU to the US.
AUTOMATED DECISIONS Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved. Blissful Elopements does not make automated decisions for Consumer data. If automated decisions are made, affected persons will be given an opportunity to express their views on the automated decision in question and object to it.
ENFORCEMENT RIGHTS AND MECHANISMS Blissful Elopements will ensure that this Policy is observed and duly implemented. All persons who have access to Personal Data must comply with this Policy. Violations of the applicable data protection legislation in the EU may lead to penalties and/or claims for damages. If at any time, a person believes that Personal Data relating to him or her has been processed in violation of this Policy, he or she may report the concern to the competent Blissful Elopements official. In particular If you have any inquires or complaints about the use or limitation of use of your personal information, you may contact Blissful Elopements corporate headquarters:
Sally Jarjoura Blissful Elopements PO Box Chattanooga, TN _______
COMMUNICATION ABOUT THE POLICY In addition to the training on this Policy, Blissful Elopements will communicate this Policy to current and new employees and consumers by posting it on Blissful Elopements website as well as on selected internal Blissful Elopements websites and by providing a link to the Policy on information technology applications where Personal Data are collected and processed.
MODIFICATIONS OF THE POLICY Blissful Elopements reserves the right to modify this Policy as needed, for example, to comply with changes in laws, regulations or requirements introduced. Changes must be approved by Blissful Elopements Privacy POCs, the office of the corporate legal department, or their designees who will seek input as they reasonably deem appropriate from corporate executives such as the CEO, CFO, COO, and Chief of Staff, for the amended Policy to enter into force. If Blissful Elopements makes changes to the Policy, this amended Policy will be submitted for renewed approval according to the relevant applicable provisions of the law. Blissful Elopements will inform Blissful Elopements Employees, Consumers and other persons (e.g. persons accessing Blissful Elopements websites to enter Personal Data) of any material changes in the Policy. Blissful Elopements will post all changes to the Policy on relevant internal and external websites. Effective with the implementation of this Policy, all existing and applicable EU company privacy guidelines relating to the collection and/or processing of Personal Data will, where in conflict, be superseded by the terms of this Policy. No other internal policy that conflicts with this Policy shall be applicable with respect to the protection of Personal Data handled by Blissful Elopements in the US & EU. All parties to such agreements will be notified of the effective date of the implementation of the Policy.
OBLIGATIONS TOWARDS DATA PROTECTION AUTHORITIES Blissful Elopements will respond diligently and appropriately to requests about this Policy or compliance with applicable data protection privacy laws and regulations. Blissful Elopements employees who receive such requests should contact their human resources manager or business legal counsel. Blissful Elopements will, upon request, provide DPAs with names and contact details of relevant persons. With regard to transfers of Personal Data between Blissful Elopements entities, the importing and exporting Blissful Elopements entities will (i) cooperate with inquiries from the DPA responsible for the entity exporting the data and (ii) respect its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third entities, Blissful Elopements will comply with DPAs’ decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.