Privacy Shield Policy

Front & Main, Inc. d/b/a Honey (“Honey,” we,” or our,”), complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, both as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of Personal Data (defined below) from European Union member countries, and Switzerland. Honey has certified that it adheres to the Privacy Shield Principles of: 1) Notice; 2) Choice; 3) Accountability for Onward Transfer; 4) Security; 5) Data Integrity and Purpose Limitation; 6) Access; and 7) Recourse, Enforcement, and Liability. If there is any conflict between the policies in this Privacy Shield Policy (“Privacy Shield Policy”) and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, the Privacy Shield Principles, or to view our certification page, please visit https://www.privacyshield.gov/list.

Definitions

“Data Subject” means the individual to whom any Personal Data is referable.

“Personal Data” means any information relating to an individual residing in the European Union and/or Switzerland that can be used to identify that individual either on its own, or in combination with other readily available data.

“Sensitive Personal Data” means Personal Data regarding an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, physical or mental health, or sexual activities.

Scope and Responsibility

This Privacy Shield Policy applies to Personal Data transferred from Honey users located within European Union member countries and Switzerland to Honey’s operations in the U.S. in reliance on the Privacy Shield framework of either the EU or Switzerland. However, the principles set forth herein may be limited or otherwise provided for in the contractual agreement entered into between Honey and the employer of the users to whom this Privacy Shield Policy is directed. You should inquire with your employer regarding how they treat your Personal Data, or how they permit their controllers to treat your Personal Data.

Privacy Shield Principles

Honey commits to subject to the Privacy Shields’ Principles, all Personal Data received by Honey in the U.S. from European Union member countries and Switzerland in reliance on the respective Privacy Shield framework.

1. Notice

Honey notifies Data Subjects covered by this Privacy Shield Policy about its data practices regarding Personal Data received by Honey in the U.S. from European Union member countries and Switzerland in reliance on the respective Privacy Shield framework, including the types of Personal Data it collects about them, the purposes for which it collects and uses such Personal Data, the types of third parties to which it discloses such Personal Data and the purposes for which it does so, the rights of Data Subjects to access their Personal Data, the choices and means that Honey offers for limiting its use and disclosure of such Personal Data, how Honey’s obligations under the Privacy Shield are enforced, and how Data Subjects can contact Honey with any inquiries or complaints.

2. Choice

If Personal Data covered by this Privacy Shield Policy is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party, Honey will provide Data Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to: optout@honey.is.

If Sensitive Personal Data covered by this Privacy Shield Policy is to be used for a new purpose that is different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a third party, Honey will obtain the Data Subject’s explicit consent prior to such use or disclosure.

3. Accountability for Onward Transfer

In the event we transfer Personal Data covered by this Privacy Shield Policy to a third party acting as a controller, we will do so consistent with any notice provided to Data Subjects and any consent they have given, and only if the third party has given us contractual assurances that it will (i) process the Personal Data for limited and specified purposes consistent with any consent provided by the Data Subjects, (ii) provide at least the same level of protection as is required by the Privacy Shield Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the Personal Data or take other reasonable and appropriate steps to remediate if it makes such a determination. If Honey has knowledge that a third party acting as a controller is processing Personal Data covered by this Privacy Shield Policy in a way that is contrary to the Privacy Shield Principles, Honey will take reasonable steps to prevent or stop such processing.

With respect to our agents, we will transfer only the Personal Data covered by this Privacy Shield Policy needed for an agent to deliver to Honey the requested product or service. Furthermore, we will (i) permit the agent to process such Personal Data only for limited and specified purposes; (ii) require the agent to provide at least the same level of privacy protection as is required by the Privacy Shield Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the Personal Data transferred in a manner consistent with Honey’s obligations under the Privacy Shield Principles; and (iv) require the agent to notify Honey if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles. Upon receiving notice from an agent that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.

Honey remains liable under the Privacy Shield Principles if an agent processes Personal Data covered by this Privacy Shield Policy in a manner inconsistent with the Principles, except where Honey is not responsible for the event giving rise to the damage.

4. Security

Honey takes reasonable and appropriate measures to protect Personal Data covered by this Privacy Shield Policy from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

5. Data Integrity and Purpose Limitation

Honey limits the collection of Personal Data covered by this Privacy Shield Policy to information that is relevant for the purposes of providing its service. Honey does not process such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the Data Subject.

Honey takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. Honey takes reasonable and appropriate measures to comply with the requirement under the Privacy Shield to retain Personal Data in identifiable form only for as long as it serves a business or processing purpose, which includes Honey’s obligations to comply with professional standards, Honey’s business purposes and unless a longer retention period is permitted by law, and it adheres to the Privacy Shield Principles for as long as it retains such Personal Data.

6. Access

Data Subjects whose Personal Data is covered by this Privacy Shield Policy have the right to access such Personal Data and to correct, amend, or delete such Personal Data if it is inaccurate or has been processed in violation of the Privacy Shield Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). Requests for access, correction, amendment, or deletion should be sent to: privacy@honey.is

7. Recourse, Enforcement, and Liability

Honey’s participation in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework is subject to investigation and enforcement by the United States Federal Trade Commission.

In compliance with the Privacy Shield Principles, Honey commits to resolve complaints about your privacy and our collection or use of your Personal Data. Data Subjects with inquiries or complaints regarding this Privacy Shield Policy should first contact Honey at: disputes@honey.is

Honey has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the International Centre for Dispute Resolution-American Arbitration Association (ICDR-AAA), operated by the American Arbitration Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://go.adr.org/privacyshield.html for more information and to file a complaint.

Under certain conditions detailed in the Privacy Shield, Data Subjects may be able to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.

Honey agrees to periodically review and verify its compliance with the Privacy Shield Principles, and to remedy any issues arising out of failure to comply with the Privacy Shield Principles. Honey acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of Privacy Shield participants.

Changes to this Privacy Shield Policy

This Privacy Shield Policy may be amended from time to time consistent with the requirements of the Privacy Shield. Appropriate notice regarding such amendments will be given. This Privacy Shield Policy was last revised on July 30, 2018.