Privacy Policy
1.
General
We at
Shinez.io (the “Company“,
“We“, “Us” or “Our“), are committed to protecting the privacy of Our users
(“You“). As part of this commitment, it is important for Us to
be transparent about how We handle the Data that We (or others on Our behalf)
collect about Our users, when We collect Data about them, and how We use such
Data.
This privacy policy (the “Policy“) provides
You with information regarding the Data collected, processed, used by the
website We operate at: https://Shinez.io (“the “Website“).
This Policy is part of and should be read in conjunction with
our Terms of Use. https://Shinez.io/ terms-of-use/
In this Policy, any reference to “Personal Data” is to any
Data relating to an identified or identifiable natural person; an identifiable
natural person is one who can be identified, directly or in combination with
additional Data that We have or that We have access to.
2.
When do
We collect Data about You?
2.1.
We may collect Personal Data about You in
the following circumstances:
2.1.1.1.
When You access or use the Website;
2.1.1.2.
When You interact with Us in any manner,
including by sending us emails or messages via third party social media
Websites such as Meta (Facebook) or in any other manner.
2.2.
You are under no legal obligation to
furnish any Data about You, and the furnishing thereof is at Your discretion
and of Your own free will. However, if You do not furnish certain Data about
You, We shall not be able to provide You with some of the Services or certain
sections on the Website.
2.3.
We do not knowingly process Data about
minors. Any person who provides the Data to Us (or to others on our behalf) in
connection with the Services represents to us that they are 16 (sixteen) years
of age (or such other lawful age – where higher than 16) or older. It is Our
policy to try and uncover attempts by minors to access the Services, and this
may require having to access and verify Your Personal Data. We will not accept
and take actions to remove from Our records any Data which we discover is or
was submitted by a minor.
3.
What
types of Data do We collect?
3.1.
We (or others on Our behalf) may collect
the following types of Personal Data about You:
3.1.1.
Communication Data – when You contact Us,
though any channel whatsoever, including social media networks, You may provide
Us with Your name, certain contact Data (such as email address) and the content
of Your communication with Us.
3.1.2.
Website usage Data – this Data includes
online activity log, traffic Data (including, without limitation, IP address,
time of access, date of access, web and mobile page(s) visited, language used,
operating system Data, Your device Data, crash reports and type of browser used,
Data regarding the device You used, including the hardware model, operating
system and version, the website You visited before entering our Website and
other device identifiers. Some of this Data may not identify You personally,
and therefore does not constitute Personal Data.
3.1.3.
Website activity Data – whenever You use the
Website, We monitor Your use of the Services and record Your activity. The Data
that We gather about You in this context includes any activity that You perform
in the Website, such as dates and times on which You will use the Website, the
length of time You will be watching content on the Website, Your interaction
with content in the Website, etc.
3.2.
You are responsible for ensuring the
accuracy of the Data that You provide Us (or others on Our behalf) with.
Inaccurate Data will affect Our ability to provide You with some of the
Services, as well as Our ability to contact You as contemplated in this Policy.
4.
The
Purposes Of The Processing Of Personal Data And Their Legal Basis
4.1.
The Company will not process Personal Data
about You unless there is a legal basis for such processing.
4.2.
The legal bases according to which We may
process Personal Data about You are as follows:
4.2.1. Your
consent that the Company will process Personal Data about You for one or more
specific purposes. By way of example, for the purpose of operating the Website.
Where the legal basis for the processing of the Personal Data about You is
consent, You may at any time withdraw Your consent for the purposes for which
You provided Your consent by sending a notice free of charge to the following
email address: [email protected].
Where You
withdraw Your consent for the processing of Personal Data about You, We might
not be able to provide You with some or all of the Services You requested or in
the form intended to be provided to You, and You will have no claim in respect
of that.
4.2.2. Processing
is necessary for the performance of a contract to which You are party or in
order to take steps at Your request prior to entering into a contract. This
refers to all the Data required for us to provide You with the Services and
grant You access to the Website and the various Services offered in connection
therewith.
4.2.3. Processing
is necessary for the purposes of the legitimate interests pursued by the
Company or by a third party. By way of example, for the purpose of improving
Our Services, or for the exercise or defense of legal claims.
4.3.
At any time, You may approach Us by
sending a notice to the email address [email protected], in order to receive
Data concerning the review performed by Us. This is so You can conclude that We
may process the Personal Data about You on account of such processing being
necessary for the purposes of the legitimate interests pursued by the Company
or by a third party.
5.
How do
We use Personal Data?
We may use
Personal Data about You for the following purposes:
5.1.
To operate the Website and provide the
Services.
5.2.
To contact You for the purpose of
operational requirements.
5.3.
To personalize content and/or offers to
You.
5.4.
To respond to Your queries, requests
and/or complaints.
5.5.
To send You materials regarding services,
events and other Data we think will be of interest to You, subject to Your
consent.
5.6.
To analyze and improve the Services, as
well as to develop and offer new ones.
5.7.
To analyze and track usage to determine
the usefulness or popularity of certain content and to better understand the
online activity of the Website users.
5.8.
Monitor and analyze trends, usage and
activities in connection with the Website and the Services.
5.9.
To perform and maintain various activities
supporting the offering and provision of the Services, including, but not
limited to, the Website (such activities include back office functions,
business development activities, strategic decision making, financing
management, etc.).
5.10. To
protect Our and third parties’ interests, rights and assets, including
detecting, investigating and preventing fraudulent transactions or unauthorized
or illegal activities and initiation or exercise or defense of legal claims and
preventing.
5.11. To
fulfill Our legal or regulatory requirements.
6.
Sharing
of Personal Data
6.1.
We will not disclose Personal Data about
You to third parties except as detailed in this Policy.
6.2.
We may transfer Personal Data to entities that control Us, entities that are under Our
control and/or to entities under common control or ownership with Us, as shall
be from time to time (collectively the “Group”).
Such entities may use the Personal Data to support the needs of the Group.
6.3.
When You are transferred to Our Website
from another third party Business partner, We may transfer Your Personal Data
that You have provided to Us to that third party Business partner;
6.4.
We may transfer Personal Data to Our Affiliates;
6.5.
In the event that We will be subject to an
audit or a Due diligence process;
6.6.
In the event that We sell, assign or
transfer some or all of Our business or assets to a successor
or acquirer, or if We are acquired by or merge with a third party, or if We
file for bankruptcy or become insolvent, or any other situation where Personal
Data may be sold, assigned or transferred to a successor or acquirer;
6.7.
To protect Our rights, property and
interest or those of third parties;
6.8.
To fulfill Our legal or regulatory
requirements or to comply with a court order;
6.9.
Upon Your consent or instruction;
6.10. In
addition, We may share Personal Data about You with the following third parties
providing Us the following services:
●
Storage and hosting providers, including
cloud computing services and data security services;
●
IP address Data;
●
Analysis of user experience;
●
Support;
●
Marketing;
●
Advertisements services;
●
CRM data management;
●
Accounting and legal services; and
●
Research, analytical, technical, and
diagnostic services.
7.
Transfer
of Personal Data abroad
7.1.
We may transfer Personal Data about You
outside the jurisdiction which You are a resident of and store it in other
jurisdictions and countries; the data protection and other laws of these
jurisdictions or countries may not be as protective to Personal Data as those
in the jurisdiction which You are resident – in these instances, We will take
steps to ensure that an appropriate level of protection is given to Your
Personal Data.
7.2.
You may request that the Company provide
You with details concerning the safeguards employed by it to protect the
Personal Data about You that are transferred to a third country or an
international organization, by sending an email to the following address: [email protected].
8.
Retention
of Personal Data
We will retain
Personal Data about You only for as long as necessary for the fulfillment of
the purposes for which such Personal Data is collected. We may retain Personal
Data about You for longer periods, if We find it necessary to comply with legal
requirements applicable to Us.
9.
Cookies
and Trackers
9.1.
We may use certain third
party services, such as analytics
companies or companies delivering advertisements, which may also use cookies or
other technologies, and those practices and providers are subject to their own
policies.
9.2. Cookie (which is
a small text file) is installed on the device via which You visit or access the
Website. The cookies allow Us to collect information about You and Your
behavior, in order to improve Your user experience, to remember Your
preferences and settings, and to customize and offer You products and services that may interest You. Cookies are also
used to collect statistics and perform analytics.
9.3. Some of the
cookies We use are session cookies, which are downloaded temporarily to Your
device and last until You close Your web browser, while others are persistent
cookies, which last on Your device after You cease browsing the Service and are
used to help the Service remember You as a returning visitor when You return to
the Service.
Types of cookies:
The cookies We may use have been
classified according to their functionality, as follows:
Type of Cookie |
Purpose |
Additional Information |
Strictly Necessary Cookies |
These
cookies are strictly necessary to enable You to navigate the Website and use
features You have requested. They are used to provide You with Our content,
products, and Website that You have requested. Such
cookies are essential to help Your device download or stream information so
that You can navigate around the Website, use its features, and return to
pages You have previously visited. |
These
cookies collect Personal Data about You, such as user name and last login
date, and identify You as being logged in to the Website. These
cookies are deleted when You close Your web browser (session cookies). |
Functionality Cookies |
These
cookies are used to recognize You when You return to the Website and allow Us
to remember Your choices and preferences and measure how You use our website.
|
These
cookies survive the closing of Your web browser, and last until their
applicable expiry time. |
Performance Cookies |
These
cookies are used to provide aggregated statistics in respect of the
performance of the Website and to test and improve such performance, in order
to provide better user experience. In addition, they allow Us to carry out
analytical functions on the Website. |
These
cookies collect anonymized data that is not related to an identified or
identifiable natural person. These
cookies are valid for varying periods; some are deleted once You close Your
browser, while others have an indefinite validity period. |
Third Party Marketing/Targeting
Cookies |
These
cookies are used to deliver ads and marketing communications, and to display the Website
in a manner that is more relevant to You. They are also used to measure the
effectiveness of an advertising campaign. These cookies record Your visit to
the Website and the pages You have visited. |
Some of
these cookies are provided and used by third parties. These
cookies are valid for varying periods; some are deleted once You close Your
browser, while others have an indefinite validity period. |
The Cookies incorporated in our
Website are as follows:
Third Party |
Name |
Retention |
Type |
Function |
No |
Shinez.io |
1 week |
Essential, Functionality and Performance. |
User experience statistics, values needed for technical
optimization |
Yes |
Google Products |
13 months (max)
|
Essential, Functionality, Performance and Targeted
Advertising |
https://business.safety.google/adscookies/ |
Yes |
GeoEdge |
|
Operation and Security |
https://www.geoedge.com/privacy |
Yes |
Cloudflare |
30 minutes |
Operation and Security |
https://developers.cloudflare.com/fundamentals/reference/policies-compliances/cloudflare-cookies/ |
Yes |
Facebook Pixel |
3 months and 1 week. |
Targeted Advertising |
https://www.facebook.com/business/help/471978536642445?id=1205376682832142 |
Blocking and removal of cookies:
You can change Your browser settings
to block and delete some or all cookies. Please see below links to instructions
on how to do this in respect of some of the most popular web browsers:
●
Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectslug=Cookies&redirectlocale=en-US
●
Edge:
https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
●
Internet Explorer:
https://support.microsoft.com/en-gb/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
●
Google Chrome:
https://support.google.com/chrome/answer/95647?hl=en
●
Safari:
https://support.apple.com/en-ph/guide/safari/sfri11471/mac
Please note, however, that if You do
so, some or all of the Service’s features and functionalities might not perform
as intended.
ONLINE TRACKING NOTICE
AT THIS TIME, THIS SERVICE DOES
NOT SUPPORT DO-NOT-TRACK SIGNALS.
10.
Security
We have
implemented suitable security policies, rules and technical measures to protect
and safeguard the Personal Data under Our control from unauthorized access,
improper use or disclosure, unauthorized modification, or unlawful destruction.
11.
Links to
Other Websites
11.1. The
Website may contain links to websites and/or applications of third parties.
Other websites and applications may also reference or link to Our Website. We
do not control such websites and applications, nor the collection and/or processing
of Personal Data about You by such websites and applications, and thus We are
not responsible for the privacy practices. This Policy does not apply to any
actions taken via such websites and/or applications.
11.2. Whenever
You access such third parties’ websites and/or applications, We recommend that
You carefully review their privacy policies prior to using such websites and/or
applications and prior to disclosing any Personal Data about You.
12.
Your rights in respect of the Personal Data about You
12.1. Generally, You have the right to request that
We provide You with confirmation as to whether Personal Data about You is being
collected by Us, to ask to review such data, to rectify the Personal Data if
applicable and to erase the Personal Data no longer required by Us.
12.2. Where the legal basis for the processing of the Personal Data
about You is consent, You may at any time withdraw Your consent for the
purposes for which You provided Your consent by sending a notice free of charge
to the following email address: [email protected].
12.3. Where You
withdraw Your consent for the processing of Personal Data about You, We might
not be able to provide You with some or all of the Services You requested or in
the form intended to be provided to You, and You will have no claim in respect
of that.
12.4. At any time,
You may approach Us by sending a notice to the email address [email protected], in
order to receive information concerning the review performed by Us. This is so
You can conclude that We may process the Personal Data about You on account of
such processing being necessary for the purposes of the legitimate interests
pursued by the Company or by a third party.
12.5. The Company may
provide You with offers that are tailored for You specifically, in order to
connect You to brands, products and services
in ways that are important to You. This may include ads, offers and other
sponsored content related to products and services
of Our’s or of third parties. This is done following the processing of Personal
Data about You, in order to adjust the materials presented to You, on the basis
of Your preferences, behavior, characteristics and interests.
If You reside in the
U.S.A, please read below with respect to the California Consumer Privacy Act
(CCPA), California Privacy Rights Act (CPRA), the Virginia Consumer Data
Protection Act (VCDPA), and the Colorado Privacy Act (CPA)) rights You
might have:
|
Right |
Scope |
1 |
Right to
know
|
You have the right to receive the following information: ●
The specific pieces of Personal Data We have
collected about You. ●
What types of Personal Data collected; ●
categories of personal data collected; ●
What are the types of sources of the Personal Data
collected; ●
the purpose of collecting the Personal Data; ●
Types of third parties with whom We share Personal
Data, if any; and |
2 |
Right of
Erasure
|
You may ask Us to delete Your Personal Data and direct Our
service providers to do so. Please note that We may not delete Your Personal Data if it
is necessary to complete Our legal obligation to You to provide the Website
or Services otherwise protect Our legal rights, comply with an existing legal
obligation; or use Your Personal Data, internally, in a lawful manner that is
compatible with the context in which You provided the information. |
3 |
Right to
non selling or sharing |
You may ask Us to not sell or share Your Personal Data. |
4 |
Right to
Non-Discrimination for the exercise of Your privacy rights |
You have the right to not be discriminated by Us because
You exercised any of Your rights under the CCPA. |
5 |
Right to
designate an authorized agent to submit CCPA requests on Your behalf |
You may designate an authorized agent to make a request
under the CCPA on Your behalf. To do so, You need to provide the authorized
agent written permission to do so and the agent will need to submit to Us
proof that such agent has been authorized by You. We will also require that
You verify Your own identity, as explained below. |
In order to exercise Your
rights, please contact us using the following details: [email protected].
If You are an EEA resident, please
read this section below:
12.6. You are entitled
to the following rights in respect of the Personal Data about You. To exercise
such rights, You may send a request to exercise Your rights to the following
email address: [email protected].
12.7. We will grant
Your right to receive information how Personal Data about You is processed by
Us; to rectify any inaccuracy in Your Personal
Data; to erase Your Personal Data
processed and stored by Us; to restrict
the processing thereof or object thereto if applicable under the circumstances;
the right to receive the Personal Data about You, which You have provided to
the Company, in a structured machine readable manner and the right to withdraw
Your consent when such is the legal basis of our processing.
12.8. We may reject
Your requests where the request harms the rights and freedoms of others or
comply with legal requirements applicable to Us. We may also charge a
reasonable fee where applicable.
12.9. You will also
have the right to lodge a complaint with a supervisory authority established by
a Member State to protect the fundamental rights and freedoms of natural
persons in relation to the processing of Personal Data within the European
Union.
12.10.
Please note that We may need to receive Personal Data
from You in order to verify Your identity prior to allowing You to exercise
Your rights.
13.1. Personal Data
about You may be transferred to a third country (i.e. jurisdictions other than
the one You reside in) or to international organizations. In such
circumstances, the Company shall take appropriate safeguards to ensure the
protection of Personal Data about You and to provide that enforceable data
subject rights and effective legal remedies for data subjects are available.
13.2. If You are an
EEA resident, please note that these safeguards and protection will be
available if any of the following are met:
13.3. The transfer is
to a third country or an international organization that the EU Commission has
decided provides an adequate level of protection to the Personal Data that is
transferred to it pursuant to Article 45(3) of Regulation (EU) 2016/679 of the
European Parliament and of the Council of 27 April 2016 (“GDPR“);
13.4. The transfer is
according to a legally binding and enforceable instrument between public
authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or
13.5. The transfer is
in accordance with standard data protection clauses adopted by the EU
Commission pursuant to Article 46(2)(c) of the GDPR.
You may
request that the Company provide You with details concerning the safeguards
employed by it to protect the Personal Data about You that are transferred to a
third country or an international organization, by sending an email to the
following address: [email protected].
14.
Changes
to the Policy
We may change
this Policy in Our sole discretion at any time. Any revisions to this Policy
will be posted as an updated version accessible via the Website home page. We
recommend that You revisit this Policy regularly so as to be kept apprised of
any such changes.
15.
Contact
Us
For any
queries relating to this Policy and data protection, please contact Us at [email protected].
This site is O&O by Shinez.io
Last updated: December 2023.