If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this GDPR Privacy Notice, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Company will be the controller of your Personal Data processed in connection with the Services.
How and With Whom Do We Share Your Data?
Fraud prevention service providers
Analytics service providers
Staff augmentation and contract personnel
Hosting service providers
Co-location service providers
Marketing Service Providers
Product Development Service Providers
Customer Success Providers
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
Social media services (if you interact with them through your use of the Services)
Third party business partners who you access through the Services
We also share Personal Data when we believe it is necessary to:
Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
Maintain the security of our products and services
We also share information with third parties when you give us consent to do so.
Last, we share Personal Data with our affiliates or other members of our corporate family. Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.
What Security Measures Do We Use?
We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity.
The Shub website uses SSL (https).
Account passwords are hashed when stored in our database.
The authenticity of request methods are verified to prevent CSRF (cross-site request forgery) attacks.
Shub employees use passwords and enable screen locking.
Access to AWS and Payment Processors is limited on a need to know basis and requires Two-Factor Authentication (2FA).
Access to production data requires VPN access which is restricted to only the people that need it.
Shub performs third-party penetration testing.
How Long Do We Retain Your Personal Data?
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
Personal Data of Children:
What Rights Do You Have Regarding Your Personal Data?
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email firstname.lastname@example.org. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data by emailing email@example.com.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by emailing firstname.lastname@example.org.
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint: You have the right to lodge a complaint about Company’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Transfers of Personal Data: The Services are operated in the Untied Kingdom and hosted on worldwide servers through the Company and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Company in the U.S. and will be hosted on U.S. servers, and you authorize Company to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to EU-U.S. or Swiss-U.S. Privacy Shield Frameworks, respectively, the details of which are further set forth below.
Company has certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU and Switzerland to the U.S., respectively. For more information about the Privacy Shield Program, and to view Company’s certification, please visit www.privacyshield.gov. Company is committed to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU and Switzerland in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Company’s compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Please contact us at email@example.com with any questions or concerns relating to our Privacy Shield Certification and to resolve your complaints. We commit to cooperate with the panel established by the EU data protection authorities (DPAs) or the Swiss Federal Data Protection and Information Commissioner, as applicable, and comply with the advice given by the panel or Commissioner. EU individuals wishing to reach their area DPA’s may locate them by going to http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. Swiss individuals wishing to contact their local FDPIC may locate them by going to https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.
What If You Have Questions Regarding Your Personal Data?
If you have any questions about this GDPR Privacy Notice or our data practices generally, please contact us using the following information: