European Union Privacy Shield Compliant Switzerland Safe Harbor Compliant NGP VAN complies with the EU-U.S. Privacy Shield Framework as set forth by the Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU to the US. Accordingly, NGP VAN is in the process of completing its certification to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program including the Principles, please visit www.privacyshield.gov. NGP VAN also maintains an affirmative commitment to the U.S.-Swiss Safe Harbor Framework and its principles, which will not be affected by our participation in the Privacy Shield. Further information on our compliance with the U.S.-Swiss Safe Harbor Framework is available on request. NGP VAN is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). NGP VAN’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, NGP VAN remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless NGP VAN is found to not be responsible for the event giving rise to the breach. We encourage interested persons to raise any concerns using the contact information provided below and we will investigate and attempt to resolve any complaints and disputes. For any complaints that cannot be resolved with NGP VAN directly, NGP VAN has chosen JAMS (https://www.jamsadr.com/eu-us-privacy-shield) as an independent recourse mechanism to facilitate alternative dispute resolution (ADR) services including binding arbitration; provided, however, certain complaints are required to be referred to EU data protection authorities (DPAs).