EETech’s GDPR Compliance Statement

Introduction

The EU General Data Protection Regulation (“GDPR”) came into force across the European Economic Area (EEA, which includes the European Union and Iceland, Lichtenstein, and Norway) on May 25, 2018, and brought with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR meets the new requirements that come with the digital age.

The 21st century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new regulation aims to standardize data protection laws and processing across the EU, affording individuals stronger, more consistent rights to access and control their personal information.

Our Commitment

EETech Media, LLC (EETech) is committed to ensuring the security and protection of the personal information that we process, as well as providing a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place, which complies with existing law and abides by the data protection principles. However, we understand and have met our obligation to update and expand this program to meet the demands of the GDPR.

EETech is dedicated to safeguarding the personal information under our remit, and we have developed a data protection regime that is effective and that demonstrates an understanding of, and an appreciation for, the new regulation. The steps we took for GDPR compliance have been summarized in this statement, and they include the development and implementation of new data protection roles, policies, procedures, controls, and measures to ensure maximum and ongoing compliance.

How We Have Prepared for the GDPR

EETech already had a consistent level of data protection and security across our organization, but we took the necessary steps to be fully compliant with the GDPR by May 25, 2018. Our preparation included:

• Information Audit: We have carried out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed, and if and to whom it is disclosed.
• Policies and Procedures: We have implemented data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
  • Data Protection: Our data protection policies include accountability and governance measures to ensure that we understand and adequately illustrate our obligations and responsibilities, with a dedicated focus on privacy by design and the rights of individuals.
  • Data Retention and Erasure: Our retention policy ensures that we meet the “data minimisation” and “storage limitation” principles of the GDPR and that personal information is stored, archived, and destroyed compliantly and ethically. Our erasure procedures meet the new “Right to Erasure” obligation and are aware of when this and other data subjects’ rights apply, as well as any exemptions, response timeframes, and notification responsibilities.
  • Data Breaches: Our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate, and report any personal data breach at the earliest possible time.
  • International Data Transfers: We process and store all data outside of the EU, specifically in the United States. We have robust procedures and safeguarding measures in place to secure, encrypt, and maintain the integrity of the data. Any data transferred from the EEA to the United States through our sites is compliant with the EU-US Privacy Shield.
  • Subject Access Request (SAR): Our SAR procedures accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply, and a suite of response templates to ensure that communications with data subjects are compliant, consistent, and adequate.
• Legal Basis for Processing: We have reviewed all processing activities to identify the legal basis for processing and have ensured that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the UK’s Data Protection Bill are met.
• Privacy Policy: Our Privacy Policy complies with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to, and what safeguarding measures are in place to protect their information.
• Obtaining Consent: Our consent mechanisms for obtaining personal data ensure that individuals understand what they are providing and why and how we use it. In addition, we have stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records. We also have an easy-to-see-and-access way to withdraw consent at any time recorded in our Privacy Policy.
• Direct Marketing: Our direct marketing includes clear opt-in mechanisms for marketing subscriptions.
• Data Protection Impact Assessments (DPIA): The GDPR requires that, when companies process data that might be considered high-risk, involved large-scale processing, or includes special category/criminal conviction data, they implement data protection impact assessments (DPIA) to make sure that data is processed securely and properly so that any security risks are minimized. EETech does not process such data, and as such, no DPIA implementation has taken place.
• Processor Agreements: If we were to use any third-party to process personal information on our behalf, we have implemented due diligence procedures for ensuring that they (as well as we) meet and understand their GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organizational measures in place, and compliance with the GDPR.
• Special Categories Data: The GDPR defines special category data as information that includes an individual’s racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union memberships, genetic information, biometric and health-related data, sexual orientation, or other related personal data of this degree. EETech does not process these categories of data, and as such, you will not be asked to consent to the collection of this data.

Data Subject Rights

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide information in our Privacy Policy that illustrates an individual’s right to access any personal information that EETech processes about them and to request information about:

• What personal data we hold about them
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from them, information about the source
• The right to have incomplete or inaccurate data about them corrected or completed, as well as the process for requesting this
• The right to request erasure of personal data or restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
• The right to lodge a complaint and who to contact in such instances

Information Security and Technical and Organizational Measures

EETech takes the privacy and security of individuals and their personal information very seriously, and we take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure, or destruction and have several layers of security measures.

GDPR Roles and Employees

EETech has designated a Data Protection Officer (DPO), who complies with the new data protection regulation. They are responsible for promoting awareness of the GDPR across the organization and implementing the new policies, procedures, and measures.

If you have any questions about our compliance with the GDPR, please contact our Data Protection Officer by email at [email protected] or at the following address:

EETech Media, LLC
ATTN: Data Protection Officer
404 S. 8th St., Ste. 203
Boise, ID 83702