- Information collected and how it is used
- Marketing and how you can manage your preferences
- Cookies, similar sites and third-party services
- How we use Personal Information
- The legal basis for using your Personal Information
- Transfers of Personal Information
- How we protect and store your information
- Use by children
- Your rights
- Important Additional Privacy Information for California Residents
- How to contact us
To read our Terms of Service, please visit this page.
1. Information collected and how it is used
1.1 Personal Information We collect information that identifies an individual or may with reasonable effort allow the identification of an individual, or may be sensitive in nature (“Personal Information“) when you:
*register with or use our Website or one of our Products.
We will ask you to provide certain Personal Information if you choose to create a ShareFeels account or use our services. This includes your name and personal email or work email. We collect this information, only if voluntarily provided by you, in order to create and authenticate your account and provide you access to our Products and services.
We also collect Personal Information when you commence direct communications via our Website enquiry form or writing to us. When you commence direct communications with us, we may retain such communications and the accompanying Personal Information in order to process your inquiries, respond to your requests and improve our services.
2. Marketing and how you can manage your preferences
We may use your Personal Information, voluntarily provided by you in the circumstances described herein, to let you know about our Products and services that we believe will be of interest to you. In all cases, we will respect your preferences for how you would like us to manage such marketing activity with you.
To protect privacy rights and to ensure you have control over how we manage marketing activities with you:
2.1 we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
2.2 you can ask us to stop direct marketing at any time – you can ask us to stop sending email marketing, by following the ‘unsubscribe’ link you will find on all the email marketing messages we send you. Alternatively, you can contact us at firstname.lastname@example.org. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g., email); and
2.3 you can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained below in the “Cookies, Similar Sites and Third-Party Services” section.
We recommend you routinely review the privacy policies and preference settings that are available to you on any social media platforms you use, as well as your preferences within your ShareFeels account.
3. Cookies, similar sites, and third-party services
A cookie is a small text file that is stored in a web browser directory by a website or an advertisement related action. Our Website uses two types of cookies: session cookies and persistent cookies. Session cookies are created temporarily in your web browser directory while you are visiting a website and are deleted once you leave the website. Persistent cookies remain in your web browser and are activated again once you visit the website that created that specific cookie.
We use these technologies in order to ensure proper operation of our Products and Website, collect information and ensure information security. Although our collection of such information is not used to personally identify users, we are still committed to giving you the opportunity to exercise your choice of opting out from our collection of such information. For removing cookies and other technologies used on our Website, please refer to the “Opt-Out Option” sub-section below.
We will not use the above technologies to collect Personal Information without obtaining your permission, unless where we are permitted to do so under applicable privacy laws.
3.2 Opt-Out Option Please note that your browser enables you to disable all cookies (if you do not know how to do this, check out the “Help” file of your browser), however, this may interfere with your use of the Website or other internet websites.
If you would like to opt-out of the cookies that our Website may use (directly by us and not by third parties as referred to below), please email us at email@example.com.
If you use a new computer, upgrade or change web browsers or take any action which results in the deletion of the “opt out” cookie, you will need to perform this opt-out process again upon any such change.
For more information about cookies including how to set your internet browser to reject cookies please go to www.allaboutcookies.org.
3.3 Third Party Websites and Services Our Products may recommend third party websites which the Product determines may be of interest to you (“Similar Sites“). Additionally, there may be links on our Website to third party websites and services such as Google Analytics and others (“Third Party Services”). We do not have control over such Similar Sites or Third Party Services, including their information collection and use practices. We are not responsible for their privacy practices or policies. We therefore recommend that you review the privacy policies of Similar Sites and Third Party Services before providing them with your Personal Information. For more information about the Third Party Services to which links are included in our Website, please contact us at hi@ShareFeels.com.
3.4 Analytics We may use certain third-party service providers to monitor and analyse the use of our Website and/or Products, including the following:
4. How we use personal information
ShareFeels will use Personal Information solely in order to provide you with our Products and services, process your inquiries, respond to your requests and improve our services.
In addition, we may share some or all of your Personal Information in the manner and for the purposes described below:
4.1 with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any Personal Information we share with them solely for the purpose of providing the contracted service to us. These include IT service providers who help manage our IT and back office systems;
4.2 with our regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order; and
4.3 we may collect and share Personal Information if required to do so as part of any legal proceedings conducted between you and ShareFeels.
5. The legal basis for using your personal information
We will only collect, use and share your Personal Information where we are satisfied that we have an appropriate legal basis to do this. This may be because:
5.1 you have provided your consent to us using the Personal Information (e.g. where you provide us with marketing consents or opt-in to optional additional services or functionality);
5.2 our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g. providing you with our Products, and services, creating your user account);
5.3 our use of your Personal Information is in our legitimate interest as a commercial organisation, subject to your interests and fundamental rights. In these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in “your rights” section below;
5.4 our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have (e.g., the disclosure of information to law enforcement or tax authorities). If you would like to find out more about the legal basis for which we process Personal Information, please contact us.
6. Transfers of personal information
Please be aware that your Personal Information may be transferred, stored and processed in countries outside your country of residence from which the information was collected, including the United Kingdom, where our servers are located, and our central database is operated. This means that your Personal Information will be subject to a different standard of data protection than that available in your country of residence. ShareFeels will take appropriate steps to ensure that transfers of Personal Information are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. To this end:
6.1 where we transfer your Personal Information outside ShareFeels or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your Personal Information. Some of these assurances are well recognised certification schemes like the EU – US Privacy Shield for the protection of Personal Information transferred from within the EU to the United States or other countries; or
6.2 where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.
6.3 Subject to applicable laws, you have a right to contact us for more information about the safeguards we have put in place to ensure the adequate protection of your Personal Information when it is transferred as mentioned above. See the “Your Rights” section below for more details. For information about your rights as a CA resident please refer to Important Additional Privacy Information for California Residents
7. How we protect and store your information
8. Use by children
We do not offer our products or services for use by children. If you are under 18, you may not use the Website, our Products or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.
9. Your rights
You may revise your Personal Information by editing your account details. You also have the right to ask ShareFeels to amend any Personal Information it holds about you if it is inaccurate or misleading by emailing us at firstname.lastname@example.org.
9.1 The following rights, which may be subject to certain exemptions, apply (in addition to the rights set forth above) to EU users:
9.1.1 You have a right to access information held about you. Your right of access can normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law.
9.1.2 You have a right to restrict the processing of your Personal Information, for example in case we no longer need your Personal Information for the initial purposes for which it was collected but it is required by you for the establishment, exercise or defence of legal claims.
9.1.3 You have a right to object to processing which has our legitimate interests as its lawful basis. We will no longer process your Personal Information upon your request, unless we have compelling legitimate grounds for the continuation of the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You may also object to our use of your Personal Information for direct marketing purposes. See the “Direct Marketing” and “Cookies” sections for how to unsubscribe, manage your marketing preferences and opt out of cookies.
9.1.4 You have a right to obtain a portable copy of Personal Information which is processed on the basis of your consent, or which is necessary for the performance of a contract between us. You have a right to have such portable copy of Personal Information transferred to another data controller in a structured, commonly used and machine-readable format;
9.1.5 You also have a right to request details of the basis on which your Personal Information is transferred outside the European Economic Area but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
9.1.6 You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
10. Important additional privacy information for california residents
In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”), which requires that we provide California residents certain specific information about how handle their personal information, whether collected online or offline. Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. It does not include publicly available data as defined by the CCPA. This section does not address or apply to our handling of publicly available information or other personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA.
Except for the Right to Opt-out and the Right of Non-Discrimination, this section does not apply to California residents with whom we transact or communicate solely in the context of providing or receiving a product or service to or from a company that employs such residents or engages such residents as contractors. This section also does not apply to personal information we collect about job applicants, independent contractors, or current or former full-time, part-time and temporary employees and staff, officers, directors or owners of ShareFeels or any affiliated entities.
10.1.1 Categories of Personal Information that We Collect, Disclose, and Sell The list below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect. As noted below, we do not sell your personal information or disclose it to third parties for a business purpose. We may disclose each of these categories of personal information to our service providers, who are not permitted to use your personal information except as necessary for performing services on our behalf. We collect these categories of personal information from the sources described in the “Information Collected and How It Is Used” section above, and for the purposes described in the “How We Use Personal Information” section above. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident.
10.1.2 Notice of Collection ShareFeels collects the following categories of personal information:
|Categories of personal information||Do we collect?||Do we disclose for a business purpose(s)||Do we sell?|
|Name, Contact Information and other Identifiers: Identifiers such as a real name, Internet Protocol (IP) address, email address, and account name.||Y||Y||N|
|Customer Records: Electronic customer records containing personal information, such as name and email address.||Y||Y||N|
|Usage Data: Electronic network activity information, including, but not limited to, information regarding a resident’s interaction with our internet website, application, or advertisement, including access logs and other activity information related to your use of any ShareFeels websites, applications or other online services.||Y||Y||N|
|Audio, Video and other Electronic Data: Audio, electronic, or similar information, such as call recordings and other audio recording (e.g., recorded meetings and webinars||N||N||N|
10.1.3 California Consumer Rights California law grants consumers certain rights and imposes restrictions on particular business practices as set forth below. California consumers have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.
10.1.3.1 Right to Opt-out of Sale of Personal Information (“Do Not Sell”). California residents have the right to opt-out of our sale of their personal information. We do not sell your personal information.
10.1.3.2 Requests for Copy, Deletion and Right to Know. Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months. Please see Submitting Requests for instructions about how to exercise your rights:
Deletion: the right to request deletion of personal information that we have collected about you, subject to certain exemptions.
Copy: the right to request a copy of the specific pieces of personal information that we have collected about you in the prior 12 months.
Right to Know (Collection): Where we have collected personal information about you, the right to request that we disclose certain information about how we have handled your personal information in the prior 12 months, including: the categories of personal information collected; categories of sources of personal information; business and/or commercial purposes for collecting and selling your personal information; and the categories of third parties/with whom we have disclosed or shared your personal information.
Right to Know (Disclosure and Sale): Where we have sold or disclosed for a business purpose your personal information, the right to request that we disclose certain information about how we have handled your personal information in the prior 12 months, including: the categories of personal information collected; categories of third parties to whom your personal information has been sold and the specific categories of personal information sold to each category of third party; categories of third parties to whom personal information has been disclosed; and the categories personal information that we have disclosed or shared with a third party for a business purpose.
10.1.3.3 Submitting Requests. You can exercise your right by:
Emailing us at email@example.com When you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the personal information we maintain about you. As part of our verification process, we may ask you to submit additional information, use identity verification services to assist us, or if you have created an account on our website or mobile app, we may ask you to sign into your account as part of our identity verification process. Please understand that, depending on the type of request you submit, to protect the privacy and security of your personal information, we will only complete your request where we are satisfied that we have verified your identity to an appropriate degree of certainty. We will l make every reasonable effort to respond to you within 45 days after we receive a verified request. If we are unable to meet this timescale, we will respond as soon as possible over the next 45-day period.
10.1.3.4 Incentives and Discrimination. The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information.
Discrimination: if consumers exercise their rights under CCPA, businesses may not discriminate against them including by denying or providing a different level or quality of goods or services or charging or suggesting that a business will charge different prices or rates or impose penalties, unless doing so is reasonably related to the value provided to the consumer by the consumer’s data.
10.1.3.5 Your California Privacy Rights under California’s Shine-the-Light Law Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to firstname.lastname@example.org. In your request, please attest to the fact that you are a California resident. Important note: Your right to obtain information regarding any of your personal information we have shared with third parties for their own marketing use was included here solely in order to satisfy legal and regulatory notice requirements, we DO NOT share any of your personal information with third parties for their own marketing use.
11. How to contact us
We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by data protection laws.
You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place of work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before your local supervisory authority.
Last updated: 15th February 2021