LAST
UPDATED: 15 october 2020
Shorely (“we,” “our,” or
“us”) values your privacy. In this Privacy Policy
(“Policy”), we describe the information we collect, how we use it,
and when and with whom we share it. This Policy applies to all sites, mobile applications,
and other online services (collectively, “Platform”) made available
by Shorely. This Policy applies only to information collected on or through the
Platform. It does not apply to information collected or obtained by or through
any other means (including, without limitation, information collected offline,
in person, over the telephone and/or by mail, or from third parties outside the
Platform). Undefined capitalized terms used herein shall have the definitions
as set forth in our Terms of Use. By accessing or using the Platform, you agree
to this Policy. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT ACCESS OR USE
THE PLATFORM.
INFORMATION
WE COLLECT
How we collect and store information depends on how you
access and use the Platform. We collect information in multiple ways including
when you provide information directly to us, when you permit third parties to
provide information to us, and when we passively collect information from you,
such as information collected from your browser or device.
INFORMATION
YOU PROVIDE DIRECTLY TO US
We may collect information from you during your use or
access of the Platform, such as:
- When you
register for an Account;
- When you
participate in polls or surveys;
- When you enroll
for electronic newsletters;
- When you
request a quote or other information;
- When you submit
or respond to a quote/communication;
- When you make a
purchase/sale;
- When you fill
out any forms on the website;
- When you enter
a sweepstakes or contest, or register for a promotion;
- When you
transmit User Content;
- When you
download or use one of our mobile applications; or
- When you
otherwise communicate with us or other users through the Platform.
This list is illustrative, not exhaustive; the Privacy
Policy applies to all use of the Platform.
The information you provide directly to us may concern
you or others and may include, but is not limited to: (a) name; (b) zip code;
(c) email address; (d) home or business telephone number; (e) home, business or
mailing address; (f) demographic information (e.g., gender, age, political
preference, education, race or ethnic origin, and other information relevant to
user surveys and/or offers); (g) date of birth; (h) insurance information; (i)
photographs; (j) information about your project, request or need; (k) video or
audio files; (l) in certain circumstances, payment and/or identity verification
information. and/or (m) any other content you include in private communications
with other users through the Platform or communications with us. It may also
include information specific to the business or service provided by you or
offering through the Platform, such as a business name, service description,
qualifications and credentials. You are not required to provide us with such
information, but certain features of the Platform may not be accessible or
available, absent the provision of the requested information.
INFORMATION
FROM AFFILIATES, SOCIAL NETWORKING SITES, AND OTHER NON-AFFILIATED THIRD
PARTIES
We may collect information about you or others through Shorely
affiliates or through non-affiliated third parties. If you access the Platform
through your social media account, you may allow us to have access to certain
information in your Facebook profile. This may include your name, profile
picture, gender, networks, user IDs, list of friends, location, date of birth,
email address, photos, videos, people you follow and/or who follow you, and/or
your posts or “likes.”
Social networking sites, such as Facebook, have their own
policies for handling your information. For a description of how these sites
may use and disclose your information, including any information you make
public, please consult the sites’ privacy policies. We have no control over how
any third-party site uses or discloses the personal information it collects
about you.
We may also collect information about you or others
through non-affiliated third parties. For example, to the extent permitted by
law, we may, in our sole discretion, ask for and collect supplemental
information from third parties, such as information about your credit from a
credit bureau, or information to verify your identity or trustworthiness, or
for other fraud or safety protection purposes. We may combine information that
we collect from you through the Platform with information that we obtain from
such third parties and information derived from any other products or services
we provide.
INFORMATION
THAT IS PASSIVELY OR AUTOMATICALLY COLLECTED
Device/Usage Information. We and our third-party
service providers, which include ad networks and analytics companies including
DoubleClick and Google Analytics, may use cookies, web beacons, and other
tracking technologies to collect information about the computers or devices (including
mobile devices) you use to access the Platform. As described further below, we
may collect and analyze information including but not limited to (a) browser
type; (b) ISP or operating system; (c) domain name; (d) access time; (e)
referring or exit pages; (f) page views; (g) IP address; (h) unique device
identifiers (e.g. IDFA or Android ID); and (i) the type of device that you use.
We may also track how frequently you access or use the Platform. We use this
information (including the information collected by our third-party service
providers) for Platform analytics (including to determine which portions of the
Platform are used most frequently and what our users like/do not like), to
assist in determining relevant advertising (both on and off the Platform), to
evaluate the success of our advertising campaigns, and as otherwise described
in this Policy.
Location Information. When you use the Platform, we may collect general
location information (such as IP address). If you install our mobile app, we
may ask you to grant us access to your mobile device’s geolocation data. If you
grant such permission, we may collect information about your precise
geolocation, and we may use that information to improve the Platform, including
providing you with location-based features (e.g. for identification of Pro
Services available near you). To deliver customized content and advertising, we
may share your location information with our agents, vendors, or advertisers.
If you access the Platform through a mobile device and you do not want your
device to provide us with location-tracking information, you can disable the
GPS or other location-tracking functions on your device, provided your device
allows you to do this. See your device manufacturer’s instructions for further details.
If you disable certain functions, you may be unable to use certain parts of the
Platform.
Cookies and Other Electronic Technologies. We and our third-party
service providers may use cookies, clear GIFs, pixel tags, and other
technologies that help us better understand user behavior, personalize
preferences, perform research and analytics, and improve the Platform. These
technologies, for example, may allow us to tailor the Platform to your needs,
save your password in password-protected areas, track the pages you visit, help
us manage content, and compile statistics about Platform usage. We also use
certain of these technologies to deliver advertisements through the Platform
that may interest you. We or our third-party service providers also may use
certain of these technologies in emails to our customers to help us track email
response rates, identify when our emails are viewed, and track whether our
emails are forwarded.
We may also use local shared objects (also known as
“Flash cookies”) to assist in delivering special content, such as
video clips or animation. Flash cookies are stored on your device, but they are
not managed through your web browser. To learn more about how to manage Flash
cookies, you can visit the Adobe website and make changes at the Global Privacy
Settings Panel.
You can choose to accept or decline cookies. Most web
browsers automatically accept cookies, but your browser may allow you to modify
your browser settings to decline cookies if you prefer. If you disable cookies,
you may be prevented from taking full advantage of the Platform, because it may
not function properly. Flash cookies operate differently than browser cookies,
and cookie management tools available in a web browser may not affect flash
cookies. As we adopt additional technologies, we may also gather additional
information through other methods.
HOW
SHORELY USES THE INFORMATION WE COLLECT
We may use your information for any of the following
reasons:
- For the
purposes for which you provided it;
- To enable you
to use the services available through the Platform, including registering
you for our services and verifying your identity and authority to use our
services;
- For customer
support and to respond to your inquiries;
- For internal
record-keeping purposes;
- To administer
surveys, sweepstakes, promotions, or contests;
- To process
billing and payment including sharing with third-party payment gateways
and payment service providers in connection with the Platform;
- To improve and
maintain the Platform and for product development;
- To address
fraud or safety concerns, or to investigate complaints or suspected fraud
or wrongdoing;
- To periodically
send promotional emails regarding new products from Shorely, special
offers from Shorely, or other information that may interest you;
- With your
consent, to contact you by text message regarding certain services or
information you have requested;
- With your
consent, to contact you by telephone or text message regarding Platform
features, improvements, or other products and services that may interest
you;
- For Shorely’s
market research purposes, including, but not limited to, the customization
of the Platform according to your interests;
- To contact you
about goods and services that may interest you or with information about
your use of the Platform;
- For other
research and analytical purposes; and
- To resolve
disputes, to protect ourselves and other users of the Platform, and to
enforce any legal terms that govern your use of the Platform.
We may combine information that we collect from you
through the Platform with information that we obtain from affiliated and
nonaffiliated third parties, and information derived from any other products or
services we provide.
We may aggregate and/or de-identify information collected
through the Platform. We may use de-identified or aggregated data for any
purpose, including without limitation for research and marketing purposes and
may also share such data with any third parties, including without limitation,
advertisers, promotional partners, sponsors, event promoters, and/or others.
We may, either directly or through third parties we
engage to provide services to us, review, scan, or analyze your communications
with other users exchanged via the Platform for fraud prevention, risk
assessment, regulatory compliance, investigation, product development, research
and customer support purposes. For example, as part of our fraud prevention
efforts, we may scan and analyze messages to prevent fraud or improper actions.
We may also scan, review or analyze messages for research and product development
purposes, as well as to debug, improve and expand product offerings. By using
the Platform, you consent that Shorely, in its sole discretion, may, either
directly or through third parties we engage to provide services to us, review,
scan, analyze, and store your communications, whether done manually or through
automated means.
WHEN
SHORELY DISCLOSES YOUR INFORMATION
Unless otherwise described in this Policy, we may also
share the information that we collect from you through the Platform as follows:
- Affiliates. We may share
your information with any Shorely affiliates.
- Consent. We may
disclose your information to nonaffiliated third parties based on your
consent to do so. Such consent includes the disclosure of your information
(a) in order to provide services or products that you have requested
(please see below for more details); (b) when we have your permission; or
(c) as described in this Policy, the Terms of Use, or any other legal
terms governing your use of the Platform.
- Service
Providers. We may provide
access to your information to select third parties who perform services on
our behalf. These third parties provide a variety of services to us
including without limitation billing, sales, marketing, advertising,
market research, fulfillment, data storage, analysis and processing,
identity verification, fraud and safety protection and legal services. As
we retain new service providers, we generally seek contractual assurances
from these service providers that they will not use your
- information in
any manner other than to help us provide you with the services and
products available from Shorely.
- Legal
Requirements. We may
disclose your information when required by law or when we believe in good
faith that such disclosure is necessary to: (a) comply with subpoenas,
court orders, or other legal process we receive; (b) establish or exercise
our legal rights including enforcing and administering agreements with
users; or (c) defend Shorely against legal claims. If we are required by
law to disclose your information, we will use commercially reasonable
efforts to notify you unless (a) we believe in our sole discretion that
providing notice could create a risk of injury or death, or that harm or
fraud could be directed to Shorely or users; or (b) we are precluded from
providing notice by law. We will attempt to provide the notice by email if
you have given us an email address. If you do not challenge the disclosure
request, we may be legally required to turn over your information.
- Protection of Shorely
and Others. We may
disclose your information when we believe it appropriate to investigate,
prevent, or take action regarding possible illegal activities, suspected
fraud, situations involving potential threats to the physical safety of
any person, violations of the Terms of Use or any other legal terms
governing use of the Platform, and/or to protect our rights and property
and the rights and property of other users.
- Business
Transfers. As we
continue to develop our business, we may sell, buy, merge or partner with
other companies or businesses, or sell some or all of our assets. In such
transactions or where there is any change of control of Shorely, user
information may be among the transferred assets.
- App Store
Providers. We may
provide your identity and mobile device identifier to third-party app
store providers (for example, the Apple App Store) to allow you to
download our mobile apps.
- Academics and
Resout users to third parties for academic and research purposes, in
anonymized or aggregated form.
Please be advised that some information you provide will
be publicly accessible. For instance, registration for an Account requires that
you provide us with your name. If you register through Facebook, the Platform
will use the name associated with your Facebook account. Your name (full name,
or in some instances, your first name and last initial) may be visible to other
users. Depending on the circumstances, your name may be attached to your
Content or information, such as scheduling of Pro Services, service requests, reviews,
participating in discussions or forums, messaging, and profile information.
Certain other people, including other users with whom you have interacted via
the Platform, will see information about you that is attached to your name. For
example (but without limitation), if you are a Customer Member seeking Pro
Services, the description you provide of your desired services, along with your
name, will be shown to some Pro Members registered in the relevant category
along with your name. Thus, other users may be able to personally identify you
based on Content you provide.
We invite you to post Content/products on or through our
Platform, including, but not limited to, your comments, pictures, and any other
information. However, please be careful and responsible whenever you are
online. If you choose to post User Content on or through the Platform, such as
through Member-to-Member messaging or through our review boards, forums, blogs,
or other postings, that information: (a) may be or may become publicly
available; (b) may be collected and used by third parties without our
knowledge; and (c) may be used in a manner that may violate this Policy, the
law, or your personal privacy.
ONLINE
ANALYTICS AND TAILORED ADVERTISING
Analytics. We may use third-party web analytics services
on the Platform, such as those of Google Analytics. These service providers use
the sort of technology described in the Information That Is Passively or
Automatically Collected section above to help us analyze how users use the
Platform, including by noting the third-party website from which you arrive.
The information collected by the technology will be disclosed to or collected
directly by these service providers, who use the information to evaluate your
use of the Platform. We also use Google Analytics for certain purposes related
to advertising, as described in the following section. To prevent Google
Analytics from using your information for analytics, you may install the Google
Analytics Opt-Out Browser Add-on.
Tailored Advertising. Third parties whose products or
services are accessible or marketed via the Platform may also place cookies or
other tracking technologies on your computer, mobile phone, or other device to
collect information about your use of the Platform in order to (a) inform,
optimize, and serve marketing content based on past visits to our websites and
other sites and (b) report how our marketing content impressions, other uses of
marketing services, and interactions with these marketing impressions and
marketing services are related to visits to our websites. We also allow other
third parties (e.g., ad networks and ad servers such as Google Analytics,
DoubleClick, Facebook and others) to serve tailored marketing to you and to
access their own cookies or other tracking technologies on your computer,
mobile phone, or other device you use to access the Platform. We neither have
access to, nor does this Policy govern, the use of cookies or other tracking
technologies that may be placed on your computer, mobile phone, or other device
you use to access the Platform by non-affiliated, third-party ad technology, ad
servers, ad networks or any other non-affiliated third parties. Those parties
that use these technologies may offer you a way to opt out of targeted
advertising as described below. You may receive tailored advertising on your
computer through a web browser. Cookies may be associated with de-identified
data linked to or derived from data you voluntarily have submitted to us (e.g.,
your email address) that we may share with a service provider in hashed,
non-human-readable form.
If you are interested in more information about tailored
browser advertising and how you can generally control cookies from being put on
your computer to deliver tailored marketing, you may visit the Network
Advertising Initiative’s Consumer Opt-Out Link and/or the Digital
Advertising Alliance’s Consumer Opt-Out Link to opt-out of receiving
tailored advertising from companies that participate in those programs. To opt
out of Google Analytics for Display Advertising or customize Google Display
Network ads, you can visit the Google
Ads Settings page. Please note that to the extent advertising
technology is integrated into the Platform, you may still receive advertising
content even if you opt out of tailored advertising. In that case, the
advertising content will just not be tailored to your interests. Also, we do
not control any of the above opt-out links and are not responsible for any
choices you make using these mechanisms or the continued availability or
accuracy of these mechanisms. If your browsers are configured to reject cookies
when you visit this opt-out page, or you subsequently erase your cookies, use a
different computer or change web browsers, your NAI or DAA opt-out may no
longer be effective. Additional information is available on NAI’s and DAA’s
websites, accessible by the above links.
When using a mobile application you may also receive
tailored in-application advertising content. Each operating system-iOS for
Apple devices, Android for Android devices, and Windows for Microsoft
devices-provides its own instructions on how to prevent the delivery of
tailored in-application marketing content. You may review the support materials
and/or the privacy settings for the respective operating systems in order to
opt-out of tailored in-application advertising. For any other devices and/or
operating systems, please visit the privacy settings for the applicable device
or contact the applicable platform operator.
PRIVACY
OF MINORS
Our Services are not designed for minors under 18. Only
persons 18 years of age or older may use the Platform. If we discover that an
individual under 18 has provided us with personal information, we will close
the account and delete the personal information to the extent required by the
Children’s Online Privacy Protection Act. We may, where permitted by law,
retain certain information internally for purposes described in this Policy.
SECURITY
We employ appropriate physical, procedural and
technological security measures, which are reasonably designed to help protect
your personal information from unauthorized access or disclosure. Shorely may
use encryption, passwords, and physical security measures to help protect your
personal information against unauthorized access and disclosure. No security
measures, however, are 100% failsafe. Therefore, we do not promise and cannot
guarantee, and thus you should not expect, that your personal information or
private communications will not be collected, disclosed and/or used by others.
You should take steps to protect against unauthorized access to your password,
phone, and computer by, among other things, signing off after using a shared
computer, choosing a robust password that nobody else knows or can easily
guess, keeping your log-in and password private, and not recycling passwords
from other websites or accounts. Shorely is not responsible for the
unauthorized use of your information nor for any lost, stolen, or compromised
passwords, or for any activity on your Account via unauthorized password
activity.
LINKS
TO EXTERNAL PLATFORMS
The Platform may contain links to other websites or
resources over which Shorely does not have any control. Such links do not
constitute an endorsement by Shorely of those external websites. You
acknowledge that Shorely is providing these links to you only as a convenience,
and further agree that Shorely is not responsible for the content of such
external websites or the protection and privacy of information you provide
while visiting such external websites.
UPDATING,
DELETING, AND CORRECTING YOUR INFORMATION
You may review, correct and delete certain information
about you by logging in to the Platform and navigating to your preferences page
in “Your Dashboard.” You must promptly update your Account
information if it changes or is inaccurate. Upon your request, we will close
your Account and remove your profile information from view as soon as
reasonably possible. We may retain information from closed Accounts in order to
comply with the law, prevent fraud, collect any fees owed, resolve disputes,
troubleshoot problems, assist with any investigations of any user, enforce our
Terms of Use, and/or for any other purposes otherwise permitted by law that we
deem necessary in our sole discretion. You should understand, however, that
once you transmit User Content through the Platform, you may not be able to
change or remove it. Once we have deactivated or removed your Account, you
agree that Shorely will not be responsible to you for retaining information
related to your Account.
YOUR
CHOICES REGARDING EMAIL COMMUNICATIONS
We may send periodic promotional or informational emails
to you. You may opt out of such communications by following the opt-out
instructions contained in the email. Please note that it may take up to 10 business
days for us to process opt-out requests. If you opt out of receiving emails
about recommendations or other information we think may interest you, we may
still send you emails about your Account or any services you have requested or
received from us.
CHANGES
TO THIS POLICY
THIS POLICY IS CURRENT AS OF THE EFFECTIVE DATE SET FORTH
ABOVE. SHORELY MAY, IN ITS SOLE AND ABSOLUTE DISCRETION, CHANGE THIS POLICY AT
ANY TIME. SHORELY WILL POST ITS UPDATED POLICY ON THE PLATFORM, SEND YOU A
MESSAGE OR OTHERWISE NOTIFY YOU WHEN YOU ARE LOGGED INTO YOUR ACCOUNT IN
ADVANCE OF THE NEW EFFECTIVE DATE. SHORELY ENCOURAGES YOU TO REVIEW THIS POLICY
REGULARLY FOR ANY CHANGES. YOUR CONTINUED ACCESS TO OR USE OF THE PLATFORM WILL
BE SUBJECT TO THE TERMS OF THE THEN-CURRENT POLICY.
CONSENT
TO TRANSFER
Our computer systems are currently based in the United
States, so your personal data will be processed by us in the United States,
where data protection and privacy regulations may not offer the same level of
protection as in other parts of the world, such as the European Union. If you
create an Account with the Platform as a visitor from outside the United
States, by using the Platform, you agree to this Policy and you consent to the
transfer of all such information to the United States, which may not offer a
level of protection equivalent to that required in the European Union or
certain other countries, and to the processing of that information as described
in this Policy.
CONTACT
US
If you have any questions about the Privacy Policy or the
Platform, please contact us by sending an email to support@shopshorely.com.