Privacy Policy

Effective as of April 6, 2020.

This Privacy Policy explains how Shareably Media, LLC and our subsidiaries and affiliates (collectively “SBLY“, “Shareably”, “we”, “us” or “our”) handle personal information that we collect though our websites and other digital properties that link to this Privacy Policy (collectively, the “Service”), through social media, in connection with our marketing activities, and through other activities described in this Privacy Policy.

Personal Information We Collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, and email and physical addresses.
• Profile data, such as your username and password that you set to establish an online account with us, and any other information that you add to your account profile.
• Communications that we exchange, including when you contact us with questions, feedback, or otherwise.
• Payment data that certain users of the RONProject provide to us so that we can make revenue share payments to them.
• Marketing data, such as your preferences for receiving communications about our products and services, and details about how you engage with our communications.
• Other information, that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our sites and other sites and online services. This information may include:

• Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, IP address, unique identifiers, the website you visited before browsing to our website, and general location information such as city, state or geographic area.
• Online activity data,, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice.

How We Use Your Personal Information

We use your personal information for the following purposes or as otherwise described at the time we collect it:

Service delivery. We use your personal information to:

• provide, operate and improve the Service and our business;
• establish and maintain your user profile on the Service;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing and advertising. We and our third party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you Shareably-related or other direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt Out of Marketing section below.
• Interest-based advertising.We may contract with third-party advertising companies and social media companies to display ads on our Service and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data, online activity data and/or geolocation data described above) over time across our Service and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. You can learn more about your choices for limiting interest- based advertising, in the Your Choices section below.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How We Share your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

Affiliates. Our subsidiaries and other corporate affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business, such as hosting, information technology, customer service, email delivery and website analytics.

Advertising partners. Third party advertising companies that collect information about your activity on the Service and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads on their platforms to those customers and similar users.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Relevant participants in business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Shareably or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Your Choices

Access or update your information.If you have registered for an account with us, you may review and update certain account information by logging into the account.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. You may continue to receive service-related and other non-marketing emails.

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Service and the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

To disable all cookies and tracking our website, click the “Disable all” button in our Cookie Notice.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.

Third party platforms. If you choose to connect to the Service through your social media account, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third party platform, that choice will not apply to information that we have already received from that third party.

LiveRamp. When you use our website, we share information that we collect from you, such as your email (in hashed form), IP address or information about your browser or operating system, with our identity partners/service providers, including LiveRamp Inc. LiveRamp returns an online identification code that we may store in our first-party cookie for our use in online and cross-channel advertising and it may be shared with advertising companies to enable interest-based and targeted advertising. To opt out of this use, please visit https://optout.liveramp.com/opt_out.

Other Sites and Services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or other online services that are not associated with us. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International Data Transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children

The Service is not intended for use by children under 16 years of age. If we learn that we have collected personal information from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.

How to Contact Us

You can reach us in the following ways:

• Email: [email protected]
• Mail:
  
  Shareably Media, LLC
  2263 Ashbourne Drive
  San Ramon, CA 94583
  

Information for California Residents

Scope. This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents when we act as a “business” as defined under the California Consumer Privacy Act of 2018 (“CCPA”), and their rights with respect to their Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. Additionally, this section does not apply to information we collect from you in the course of communicating with you in your capacity as an employee, controlling owner, director, officer or contractor of an organization (i.e., company, partnership, sole proprietorship, non-profit or government agency) in the context of performing due diligence on, or providing or receiving products or services to or from, that organization. In some cases we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected the Personal Information.
  • The categories of third parties with whom we share the Personal Information.
  • The categories of Personal Information that we sold or disclosed for a business purpose.
  • The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
  • The business or commercial purpose for collecting and/or selling Personal Information.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Opt-out of sales. If we sell your Personal Information, you can opt-out of those sales.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA

How to exercise your rights

You may submit requests to exercise your California privacy rights described above as follows:

• Right to information, access and deletion. You may submit requests to exercise your right to information, access or deletion by:
  • visiting our Cookie Notice
  • emailing [email protected]
• Right to opt-out of the “sale” of your Personal Information. Like many companies, we use services that help deliver interest-based ads to you and have done so during the past 12 months. Our use of some of these services may be classified under California law as a “sale” of your Personal Information to the advertising partners that provide the services because they collect information from our users (e.g., device data and online activity data) to help them serve ads more likely to interest you. You can opt-out out of this use of your personal information here: Do Not Sell My Personal Information.]

We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorized agent permission to submit the request. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Personal information that we collect, use and disclose

The chart below describes the Personal Information we collected and disclosed during the 12 months preceding the effective date of this Privacy Policy by reference to the categories of Personal Information specified in the CCPA. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

Statutory category of personal information (PI) (Cal. Civ. Code § 1798.140)	PI we collect in this category (See Personal information we collect above for description)	We disclosed
Identifiers	Contact data Profile data	No
Commercial Information	Profile data Payment data Marketing data Online activity data	Yes
Financial Information	Payment data	Yes
Online Identifiers	Profile data Device data	No
Internet or Network Information	Marketing data Device data Online activity data	No
Geolocation Data	Device data	Yes
Inferences	May be derived from any of the information above. Payment data Marketing data Device data Online activity data	No

We describe the sources from which we collect this Personal Information in the section above entitled Personal Information We Collect. We describe the business and commercial purposes for which we collect this Personal Information in the section above entitled How We Use Your Personal Information. We describe the categories of third parties with whom we share this Personal Information in the section above entitled How We Share Your Personal Information.

Information Regarding the European Economic Area

Notice to European Users

This section applies only to individuals in the United Kingdom and the European Economic Area.

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller. Shareably is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

EU representative. Our EU representative is:

GDPR-Rep.eu
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o Shareably Media, LLC
Schellinggasse 3/10, 1010 Vienna, Austria

Legal bases for processing. The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us at [email protected].

Processing purpose (click link for details) Details regarding each processing purpose listed below are provided in the section above titled “How We Use Your Personal Information”.	Legal basis
Service delivery	Processing is necessary to perform the contract governing our provision of the Service or to take steps that you request prior to signing up for the Service. Where we cannot process your personal data as required to operate the Service on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the Service you access and request.
Marketing and advertising	Processing is based on your consent where that consent is required by applicable law. Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business.
Research and development Compliance and protection	These activities constitute our legitimate interests.
Compliance with legal obligations	Processing is necessary to comply with our legal obligations.
Actions we take with your consent	Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service.

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive peronal information

We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.

Retention

We retain personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested; to comply with applicable legal, tax or accounting requirements; to establish or defend legal claims; or for fraud prevention). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your rights

European data protection laws give you certain rights regarding your personal information. If you are located within the United Kingdom or European Economic Area, you may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information.
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information.
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests by email to [email protected] or our postal address provided above in the How To Contact Us section. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Cross-Border Data Transfer

If we transfer your personal information from the United Kingdom or European Economic Area to a country such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.