SloopStash Privacy Notice

Effective Date: June 25, 2018

SLOOPSTASH TECHNOLOGIES PRIVATE LIMITED (collectively “SloopStash”, "we", "us", and "ours") is committed to protecting your privacy. This Privacy Notice (“Notice”) describes how SloopStash processes Personal Data in its capacity as a controller (i.e. SloopStash decides what Personal Data is collected and what it is used for) or processor (i.e. SloopStash only processes the data as per the controller's instructions), as the case may be. It also describes your choices regarding use, access and correction of your Personal Data.

DEFINITIONS

The capitalized terms used in this Notice but not defined herein shall have the same meaning as defined in the Terms of Service at https://sloopstash.com/terms.html(“Terms”).

WHOM DOES THIS NOTICE APPLY TO?

This Notice applies to (i) entities or individuals, excluding End-Users and Users, who have subscribed to our Service(s) and have agreed to the Terms (hereinafter referred to as the “Customer”) and (ii) individuals (“Individuals”) from whom SloopStash collects data as a controller as specified below.

ANY QUESTIONS?

If you have questions or complaints regarding our privacy notice or practices, please contact us at support@sloopstash.com.

WHAT PERSONAL DATA DOES SLOOPSTASH COLLECT AND WHY?

A) Personal Data we collect and process for our own purposes: Collected Data

When you visit our Websites or participate in SloopStash’s events, SloopStash may collect information, which may include Personal Data, from Individuals as set forth below (collectively referred to as “Collected Data”). For the purposes of General Data Protection Regulation (GDPR), SloopStash shall be the controller for the Collected Data – this means that SloopStash decides what Collected Data is processed and why.

When does SloopStash process Collected Data?

1) Sign-up, billing and Account information.

When you subscribe and sign-up to any of our Service(s), we may collect your (i) contact information such as name, e-mail address, mailing address, IP address, company name, geographic location, or phone number of the Account admin; (ii) name and e-mail address when Account admin provide feedback from within the Service(s); and (iii) unique identifiers, such as username and password.

2) Program Registrations.

When you register for any of our programs through a registration form on our Websites, we may collect information such as name, e-mail address, company name and website URL, company details, location and contact information. Subject to this Notice, we will use such data, including without limitation, to (i) facilitate your use of the program portal for which you have registered; (ii) send you communication from within the Service(s); (iii) send you requested information about our Service(s); (iv) respond to your requests, questions and concerns; and (v) send you promotional and marketing communications (where you have requested us to do so).

3) Public forums and Newsletters.

When you visit our publicly accessible community forums and blogs, you should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Further, we may collect your (i) contact information such as name, e-mail address, mailing address, or phone number; (ii) information about your business, such as company name, company size, business type; and (iii) a short bio about you to identify you as the author of the post. When you actively subscribe to our newsletters, we collect your e-mail address to share our newsletters with you.

Subject to this Notice, we will use such data, including without limitation, to (i) assess needs of your business to determine or suggest suitable Service(s); (ii) send you requested information about the Service(s); (iii) send you promotional and marketing communications (where you have requested us to do so); and (iv) respond to your questions and concerns.

4) Clear Gifs and Log Files.

We and our third party advertising partners use technologies such as web beacons in analyzing trends, administering the website, tracking users movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We link this automatically collected data to other data we collect about you.

5) Analytics.

Apart from the aforementioned information collected by us, we automatically receive and record certain Personal Data of yours when You visit our Websites. This includes device model, IP address, the type of browser being used, usage pattern through cookies and browser settings, query logs and product usage logs. We also collect clicks, scrolls, conversion and drop-off on our Websites and Service(s) to render user journey at real-time. Subject to this Notice, we will use such data, including without limitation, to (i) assess needs of your business to determine or suggest suitable Service(s); (ii) send you requested information about the Service(s); (iii) respond to customer service requests, questions and concerns; and (iv) for analytical purposes.

You authorize SloopStash and its service providers to perform analytics on such Collected Data, to (i) improve, enhance, support and operate the Websites; and (ii) compile statistical reports and record insights into usage patterns. You acknowledge that SloopStash uses Collected Data, as the case may be, for the aforementioned purposes.

6) Testimonials.

We may post your testimonials/comments/reviews on our Websites which may contain your Personal Data. Prior to posting the testimonial, we will obtain your consent to post your name along with the testimonial. If you want your testimonial removed, please contact us at support@sloopstash.com.

7) Marketing communications.

We may use your e-mail address, collected as part of Collected Data, to send our newsletters and/or marketing communications about our products and services. Where you have so requested, we will also send you marketing communications about our third party partners. If you no longer wish to receive these communications, you can opt out by following the instructions contained in the e-mails you receive or by contacting us at support@sloopstash.com.

B) Data we process on your behalf: Service Data

We only process Service Data as per our Customer's instructions. For purposes of the GDPR and the Swiss Federal Act on Data Protection, we are the processor and not the controller of the Service Data. Service Data, as defined in the Terms, means all electronic data, text, messages or other materials, including Personal Data of Users and End-Users, submitted to the Service(s) by our Customers through Customer’s Account in connection with Customer’s use of the Service(s), including data collected under “Other Information” and “Mobile Applications” below. Our EEA or Switzerland based Customers are the “controllers” of that data and are responsible for compliance with the applicable data protection law. We work with our Customers to help them provide notice to their customers concerning the purpose for which Personal Data is processed by SloopStash.

If you are our Customer from EEA or Switzerland, then in your role as a controller, you are authorizing, on behalf of you and your authorized agents and End-Users, and representing that you have the authority to provide such authorization to the processing and transfer of Personal Data in and to the United States and other countries which may have different privacy laws from your or their country of residence. We will take all steps reasonably necessary to ensure that the Service Data is treated securely and in accordance with this Notice.

We do not own, control or direct the use of Service Data, and in fact we are largely unaware of what information is being stored on our platform and only access such information as reasonably necessary to provide the Service(s) (including to respond to support requests), as otherwise authorized by Customers or as required by law. Unless we explicitly agree otherwise in writing, you will not process sensitive personal data (such as health data) on our platform.

As the controller, it shall be your responsibility to inform the End-Users about the processing, and, where required, obtain necessary consent or authorization for any Personal Data that is collected as part of the Service Data through your use of the Service(s). As the processors of Personal Data on behalf of our Customers, we follow Customer’s instructions with respect to the Service Data to the extent consistent with the functionality of our Service(s). In doing so, we implement technical, physical and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to, Personal Data.

Other Information.

Where an User or End-User uses the Service(s), we automatically receive and record certain information of such user. This information includes device model, IP address, the type of browser being used, usage pattern through cookies and browser settings, query logs and product usage logs (collectively referred to as “Other Information”).

Improving and enhancing our Service(s).

You expressly authorize us and the service providers we use to process the Service Data in our systems to (i) provide, improve, enhance, support and operate the Service(s) and its availability; (ii) develop new products and services; and (iii) compile statistical reports and record insights into usage patterns.

SOCIAL MEDIA FEATURES

Our Websites includes social media features, such as the Facebook “Like” button, the “Share This” button or interactive mini-programs. Where you interact with these features, they may collect your IP address, which page you are visiting on our Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Websites. Your interactions with these features are governed by the privacy notice of the company providing them.

SHARING OF PERSONAL DATA

Except as outlined in this Notice and the Terms, Personal Data contained in Collected Data and Service Data will never be sold to or shared with other companies or organizations for commercial purposes. We process Personal Data in the United States and the European Economic Area (“EEA”) and in other countries through third parties that we may use. Third parties with whom Collected Data is shared may include third-party payment processors who process your credit card and other payment information for SloopStash but are otherwise not permitted to store, retain or use such information. Third parties that we utilize to assist in providing the Service(s) with whom Service Data may be shared are called “Sub-Processors”. Further, we may transfer Personal Data within us for the purposes identified in the Terms and this Notice. All such transfers are covered by the service agreements with the relevant recipients and we have taken appropriate safeguards to ensure that your Personal Data will remain protected in accordance with this Privacy Notice. Further details can be provided upon request.

Subject to the Terms and this Notice, we shall have the right to access Customer’s Account and to process Service Data solely to the extent necessary to provide, enhance and improve the Service(s), including, without limitation, in response to Customer’s support requests. Our Sub-Processors will only be given access to Customer’s Account and Service Data as is reasonably necessary to provide the Service(s) and will be subject to confidentiality obligations in their service agreements.

HOW DOES SLOOPSTASH KEEP PERSONAL DATA SECURE?

We use appropriate technical and organizational measures to protect the Personal Data that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data.

OTHER COMMUNICATIONS

If you are our Customer, we will send you announcements related to the Service(s) on occasions when it is necessary to do so. For instance, if our Service(s) is temporarily suspended for maintenance, we might send you an e-mail. Generally, you may not opt-out of communications which are not promotional in nature. If you do not wish to receive them, you may deactivate your Account.

LINKS TO THIRD PARTY SITES

Our Websites contain links to other websites that are not owned or controlled by SloopStash. Please be aware that we are not responsible for the privacy practices of such other websites or third parties. We encourage you to be aware when you leave our Websites and to read the privacy policies of each and every website that collects Personal Data.

CHILDREN'S PERSONAL DATA

SloopStash does not knowingly collect any Personal Data from children under the age of 16. If you are under the age of 16, please do not submit any Personal Data through our Websites or Service(s). We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Notice by instructing their children never to provide Personal Data through our Service(s) or Websites without their permission. If you have reason to believe that a child under the age of 16 has provided Personal Data to us through our Websites or Service(s), please contact us and we will endeavor to delete that information and terminate the child's account from our databases.

AMENDMENTS

Amendments to this Notice will be posted to this URL and will be effective when posted. If we make any material changes, we will notify you by means of a notice on this Website prior to the change becoming effective and if you are our Customer, via e-mail (specified in your Account). Provided we will not be notifying you if we amend the Notice to make addition, deletions or modifications to the list of cookies from time to time to keep the list of cookies current and accurate. You should frequently visit this Notice to check for amendments. Your continued use of our Websites or the Service(s) following the posting of any amendment, modification, or change to this Notice shall constitute your acceptance of the amendments to this Notice. You can choose to discontinue use of the Websites or Service(s), if you do not accept the terms of this Notice, or any modified version of this Notice.

LEGAL DISCLOSURE

We reserve the right to disclose your personal data contained in Collected Data and Service Data as required by applicable law, in response to lawful requests by public authorities, including meeting national security or law enforcement requirements and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or other legal process served on us. Collected Data and Service Data will also be shared within us for the activities permitted under the Terms and this Notice.

In the event SloopStash goes through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, Customer’s Account, Collected Data and Service Data will likely be among the assets transferred. A prominent notice will be displayed on our Websites to intimate you of any such change in ownership or control and Customers will be notified via an e-mail from support@sloopstash.com.

CONTACTING SLOOPSTASH

If you have any questions about this privacy notice or your dealings with the SloopStash, you can contact us at legal@sloopstash.com.