Even though we will comply with all legal privacy collection, storage and usage requirements of your jurisdiction, if you are:
If there is a difference in the compliance obligations between the GDPR and the CCPA then we will comply with the higher standard as regards to the minimum protection of the information collected by us.
In circumstances where there are no applicable local data protection laws, we will still handle your personal information in the manner described below.
It is your responsibility to seek advice regarding the implications of local laws.
“Personal information” essentially means information or an opinion about an identified living individual or an individual who is reasonably identifiable:
The precise definition of “personal information” or “personal data” may vary depending on which law governs the collection of the data. For example, in most jurisdictions, information relating to deceased individuals is not classified as “personal information”, but this is not universally the case.
Furthermore, legislation in some jurisdictions contains exemptions which may impact upon our privacy obligations. For example, in Australia employee records are generally exempt from an organisation’s obligations under the Privacy Act 1988, although we nevertheless
treat such records as confidential.
Note that this policy only applies to our handling of your personal information and does not relate to any aggregated, anonymised or other information which may be developed or created internally by us, provided this other information cannot later be used or combined with other data to identify you in any way.
The kind of personal information that we collect from you will depend on how you use the website and the ShareRing App. The personal information which we collect and hold about you may include:
We do not generally collect personal information about you, except when you provide that personal information voluntarily through the ShareRing App. We do not collect your private key that is generated by the ShareRing App. The private key will correspond to the public key used for your ShareRing address. Your private key will be stored in a secure location embodied in your smartphone.
You will be required to provide certain personal information when you activate the ShareRing App which will be stored by us for future reference and communication. By voluntarily providing us with information about yourself, you are consenting to our use of both the data that you provide and the data that we collect on our websites and online services in accordance with this policy.
When you access or use our Services, we may also automatically collect information about you (which may or may not be protected “personal information”), including:
In addition to personal information which we collect directly from you, and information that is automatically collected from you as explained above, we may in some circumstances be provided with information from third parties. In such a case, we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
The purpose for which we collect personal information is to provide you with the best service possible when you use our website or the ShareRing App.
It is not possible for us to provide our service to you as intended unless basic user information, interactive messages, relevant background material, and debit/credit card details, as described above, are collected directly from you.
With respect to personal information, which is automatically collected, as described above, the reason for collection is to improve and refine our service delivery to you. The specific ways in which personal information may be used to improve and refine our service delivery to you include the following:
As noted above, your personal information may be disclosed to third parties to the extent this is necessary and consistent with the purpose of collection. In addition, it may be shared as follows:
We may be required to disclose your personal information if such disclosure is:
Except as provided above, your personal information will not be shared with other parties unless:
We take reasonable steps to ensure your personal information is accurate, up-to-date, and complete. To help us achieve this:
Such corrections may take time as we will only correct such information once we have verified that the new information is correct, and we have verified that it is you who have asked for the alteration.
We undertake to use our reasonable endeavours to protect your personal information from misuse, interference and loss, and from unauthorised access, modification and disclosure.
Subject to the foregoing, we do not guarantee or warrant the security of your personal information. No system is 100% secure. The Services that we provide use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information related to debit and credit card numbers which is transmitted between you and us. We also encrypt all other data in accordance with industry standard encryption technology.
To maximize security, we will not retain your personal information when it is no longer required in connection with the original purpose of collection, unless we are under a legal obligation to the contrary.
If you are:
If you request us to provide you with access to personal information, we hold about you, then we will generally provide such information in a timely manner to you after we have verified that such access has been requested by you. There may, however, be legal grounds upon which we may, or must, withhold access in response to a request. Forexample, we may legally withhold any requested access if we honestly believe that such access could potentially harm a third party.
If you use our services, you consent to the receipt of ShareRing direct marketing material. We may send direct marketing material concerning any new services that we intend to introduce as part of our business operations. We will only use your personal information for this purpose if we have collected such information directly from you. We do not use sensitive personal information in direct marketing activity. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature. An alternative means of opting out is to contact us as set out below and simply request that you receive no further such communications.
You can withdraw your consent at any time – if you are subject to the GDPR, see the “Specific Consent” segment below.
For purposes of operational efficiency, your personal information may be disclosed to recipients in another jurisdiction. You consent to this in the knowledge that if your personal information is mishandled in another jurisdiction, we disclaim responsibility and you may not have a remedy under the law of your home jurisdiction.
Even if you are located outside Europe or the UK, the European Union General Data Protection Regulation (GDPR) and the UK equivalent may in some circumstances provide you with additional rights. Where and to the extent this is the case, we will not handle your personal information in a manner inconsistent with that law.
Where you are subject to the GDPR (or UK equivalent), or in circumstances where we have contractually committed to handle your personal information in accordance with GDPR principles, your additional individual rights will include:
We use “cookies” to collect information.
A cookie is a small data file that most major web sites write to your hard drive for record keeping purposes when you visit them. Cookies allow us to measure activity on the web site and to improve your user experience, for example by remembering your passwords and viewing preferences, thus allowing you to visit various member-only parts of the web site without re-registering. Cookies are used by us to measure activity on the web site and through our ShareRing App and make improvements and updates based on which areas are popular and which are not.
If you have a complaint concerning the manner in which we maintain the privacy of your personal information, please contact us as set out below. All complaints will be considered by our privacy officer and we may seek further information from you to clarify your concerns. If we agree that your complaint is well-founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may wish to refer the matter to the regulator or seek independent legal advice.
you can contact firstname.lastname@example.org.