SHORELESS Pri­vacy Pol­icy

What Infor­ma­tion SHORELESS col­lects, and what we do with it

Last Change: Decem­ber, 1st 2017

We at SHORELESS Limited, along with our affil­i­ates (col­lec­tively, "SHORELESS"), respect your con­cerns about pri­vacy. This Pri­vacy Pol­icy describes the types of per­sonal infor­ma­tion we col­lect about you, how we may use the infor­ma­tion and with whom we may share it. The Pri­vacy Pol­icy also describes the mea­sures we take to safe­guard the per­sonal infor­ma­tion.

In addi­tion, we tell you how you can ask us to (i) access or change the per­sonal infor­ma­tion we main­tain about you, (ii) with­draw con­sent you pre­vi­ously pro­vided to us, (iii) refrain from send­ing you cer­tain com­mu­ni­ca­tions, and (iv) answer ques­tions you may have about our pri­vacy prac­tices.


1 Information we obtain

We may obtain your per­sonal infor­ma­tion (such as name, con­tact details and pay­ment infor­ma­tion) in con­nec­tion with var­i­ous activ­i­ties such as (i) use of the SHORELESS web­sites and appli­ca­tions, (ii) ship­ping activ­i­ties, (iii) sup­port requests and other requests to answer ques­tions, (iv) events in which we par­tic­i­pate, and (v) pro­mo­tions and other offers.

The types of per­sonal infor­ma­tion we may obtain include:

  • Indi­vid­ual and busi­ness con­tact infor­ma­tion; such as name, com­pany name, phys­i­cal address, email address, and tele­phone or fax num­ber.
  • Ship­ping infor­ma­tion; such as ship­ping-related con­tact details like name, phys­i­cal address, email address and tele­phone num­ber.
  • Names, email addresses and tele­phone num­bers of oth­ers to whom we are asked to send infor­ma­tion.
  • Infor­ma­tion pro­vided in response to sur­veys.
  • User­name, (hashed) pass­word and other cre­den­tials used to access the SHORELESS Web­sites, Ser­vices and prod­ucts.
  • Social media han­dles, con­tent and other data posted on our offi­cial social media pages or else­where on the Inter­net (such as other pub­lic loca­tions), and infor­ma­tion (such as email address and other infor­ma­tion you allow to be shared) we obtain through SHORELESS-related social media apps, tools, wid­gets and plug-ins (includ­ing third-party login ser­vices such as "Login with LinkedIn, Face­book, GitHub, Twit­ter, Google, Stack­Over­flow").
  • Pay­ment infor­ma­tion and finan­cial infor­ma­tion; includ­ing pay­ment card details or online pay­ment ser­vices num­ber, billing address and bank account num­bers.
  • Tax iden­ti­fi­ca­tion num­ber in cir­cum­stances in which you request Ser­vices and prod­ucts for which this infor­ma­tion is required, or in con­nec­tion with cer­tain pro­mo­tions or sweep­stakes.
  • Other per­sonal infor­ma­tion that may be pro­vided to us to obtain a SHORELESS Ser­vice or prod­uct.

In addi­tion, when you visit our web­sites, use our apps, or inter­act with SHORELESS-related tools, wid­gets or plug-ins, we may col­lect cer­tain infor­ma­tion by auto­mated means, such as cook­ies and web bea­cons. The infor­ma­tion we col­lect in this man­ner includes:

  • IP address
  • Geo­graphic loca­tion
  • Unique device iden­ti­fier
  • Browser char­ac­ter­is­tics
  • Device char­ac­ter­is­tics
  • Oper­at­ing sys­tem
  • Lan­guage pref­er­ences
  • refer­ring URLs
  • Infor­ma­tion on actions taken
  • Dates and times of activ­ity

A "cookie" is a text file that web­sites send to a vis­i­tor's com­puter or other Inter­net-con­nected device to uniquely iden­tify the vis­i­tor's browser or to store infor­ma­tion or set­tings in the browser. A "web bea­con" also known as an Inter­net tag, pixel tag or clear GIF, links web pages or apps to web servers and may be used to trans­mit infor­ma­tion back to a web server.

Through these auto­mated col­lec­tion meth­ods, we obtain and store "click­stream data" to tell us usage pat­terns. We may link cer­tain data ele­ments we have col­lected through auto­mated means, such as your browser infor­ma­tion, with other infor­ma­tion we have obtained about you to let us know, for exam­ple, whether you have opened an email we sent to you.

We also may use third-party ana­lyt­ics tools that col­lect infor­ma­tion about vis­i­tor traf­fic on our web­sites or apps. Your browser may tell you how to be noti­fied when you receive cer­tain types of cook­ies or how to restrict or dis­able cer­tain types of cook­ies. Please note, how­ever, that with­out cook­ies you may not be able to use all of the fea­tures of our web­sites or apps.

Both we and oth­ers (such as our adver­tis­ing net­works) may col­lect per­sonal infor­ma­tion about our vis­i­tors' online activ­i­ties, over time and across third-party web­sites, when using our web­sites and apps.

The providers of third-party apps, tools, wid­gets and plug-ins on our web­sites and apps, such as Face­book "Like" but­tons, also may use auto­mated means to col­lect infor­ma­tion regard­ing your inter­ac­tions with these fea­tures. This infor­ma­tion is sub­ject to the pri­vacy poli­cies or notices of these providers.


2 How we use the Information we obtain

We may use the infor­ma­tion we obtain to:

  • Pro­vide Ser­vices and prod­ucts you request; such as con­sult­ing, soft­ware devel­op­ment, host­ing ser­vices, and IT infra­struc­ture man­age­ment ser­vices.
  • Process and col­lect pay­ments.
  • Pro­vide client sup­port and respond to and com­mu­ni­cate with you about your requests, ques­tions and com­ments.
  • Estab­lish and man­age your SHORELESS accounts; includ­ing your online user account on our Web­sites and its var­i­ous fea­tures, such as Prod­uct Related Sys­tems and the SHORELESS Billing Cen­ter.
  • Offer you Ser­vices and prod­ucts we believe may be of inter­est for you.
  • Com­mu­ni­cate about, and admin­is­ter your par­tic­i­pa­tion in, spe­cial events, pro­grams, sur­veys, con­tests, sweep­stakes, and other offers or pro­mo­tions.
  • Enable you to post on our knowl­edge base and blogs, and inter­act with SHORELESS through social media.
  • Send infor­ma­tion to your con­tacts, employ­ees and busi­ness part­ners, if you ask us to do so.
  • Process claims we receive in con­nec­tion with our Ser­vices.
  • Oper­ate, eval­u­ate and con­stantly improve our busi­ness; includ­ing devel­op­ing new Ser­vices and prod­ucts, man­ag­ing our com­mu­ni­ca­tions, deter­min­ing the effec­tive­ness of our sales, mar­ket­ing and adver­tis­ing, ana­lyz­ing and enhanc­ing our Ser­vices, prod­ucts, Web­sites, and apps, and per­form­ing account­ing, audit­ing, billing, rec­on­cil­i­a­tion and col­lec­tion activ­i­ties.
  • Per­form data analy­ses; includ­ing mar­ket and client search, trend analy­sis, finan­cial analy­sis, and anonymiza­tion of per­sonal infor­ma­tion.
  • Pro­tect against, iden­tify and pre­vent fraud and other crim­i­nal activ­ity, claims and other lia­bil­i­ties.
  • Com­ply with applic­a­ble legal require­ments and our poli­cies.

In addi­tion, we use infor­ma­tion col­lected online through cook­ies, web bea­cons and other auto­mated means for pur­poses such as:

  1. Cus­tomiz­ing our users' vis­its to our Web­sites, and apps.
  2. Deliv­er­ing con­tent (includ­ing adver­tis­ing) tai­lored to our users' inter­ests and the man­ner in which our users browse our Web­sites and apps.
  3. Man­ag­ing our busi­ness.

We may sup­ple­ment data we col­lect through auto­mated means with infor­ma­tion about your loca­tion (such as your ZIP or postal code) to pro­vide you with con­tent that may be of inter­est to you. We also use this infor­ma­tion to help diag­nose tech­ni­cal and ser­vice prob­lems, admin­is­ter our Web­sites and apps, iden­tify users of our Web­sites and apps, and gather demo­graphic infor­ma­tion about our users.

We use click­stream data to deter­mine usage pat­terns and how we may tai­lor our Web­sites and apps to bet­ter meet the needs of our users. Our Web­sites and apps are not designed to respond to "do not track" requests from browsers.

We also may use the infor­ma­tion we obtain about you in other ways for which we pro­vide spe­cific notice at the time of col­lec­tion.


3 Information we share

SHORELESS does not sell or oth­er­wise shares per­sonal infor­ma­tion about you, except as described in this Pri­vacy Notice. To per­form deliv­ery ser­vices, we share ship­ping infor­ma­tion with third par­ties such as ship­pers, con­signees, and third party pay­ors. We also share per­sonal infor­ma­tion with third par­ties who per­form ser­vices on our behalf based on our instruc­tions. These third par­ties are not autho­rized by us to use or dis­close the infor­ma­tion except as nec­es­sary to per­form ser­vices on our behalf or com­ply with legal require­ments.

We also may share the per­sonal infor­ma­tion we obtain with our affil­i­ates, fran­chisees, resellers and joint mar­ket­ing part­ners. These enti­ties, which col­lec­tively are referred to here as the "SHORELESS Busi­ness Part­ners", may use the infor­ma­tion for the pur­poses described in this Pri­vacy Notice. We may share per­sonal infor­ma­tion with our SHORELESS Busi­ness Part­ners and other third par­ties to, for exam­ple, cre­ate tar­geted solu­tions that fully meet your needs and to develop accu­rate and up-to-date appli­ca­tions.

Infor­ma­tion col­lected through third-party apps, tools, wid­gets and plug-ins (such as infor­ma­tion obtained through third-party login ser­vices or relat­ing to your use of a Face­book "Like" but­ton) is col­lected directly by the providers of these fea­tures. This infor­ma­tion is sub­ject to the pri­vacy poli­cies of the providers of the fea­tures, and SHORELESS is not respon­si­ble for those providers' infor­ma­tion prac­tices.

Many of our clients out­source all or a part of their IT man­age­ment to us. Through our IT infra­struc­ture, Roll-Out and IT sup­port busi­ness units, we man­age the IT needs of our clients, focus­ing on process opti­miza­tion, real-time mon­i­tor­ing, and sup­port ser­vices for our clients world­wide. We also pro­vide infor­ma­tion tech­nol­ogy sys­tems and dis­tri­b­u­tion facil­i­ties adapted to the unique needs of spe­cific indus­tries such as health care, tech­nol­ogy and con­sumer/retail busi­nesses. In the course of pro­vid­ing our ser­vices, we may obtain, use and dis­close per­sonal infor­ma­tion about our clients' cus­tomers. In these cir­cum­stances, we process the infor­ma­tion based on the agree­ment with our clients.

SHORELESS also may dis­close infor­ma­tion about you:

  1. if we are required to do so by law, reg­u­la­tion or legal process (such as a court order or sub­poena),
  2. in response to requests by gov­ern­ment agen­cies, such as law enforce­ment author­i­ties, or
  3. when we believe dis­clo­sure is nec­es­sary or appro­pri­ate to pre­vent phys­i­cal harm or finan­cial loss or in con­nec­tion with an inves­ti­ga­tion of sus­pected or actual ille­gal activ­ity.

We reserve the right to trans­fer any infor­ma­tion we have about you in the event we sell or trans­fer all or a por­tion of our busi­ness or assets (includ­ing in the event of a reor­ga­ni­za­tion, dis­so­lu­tion or liq­ui­da­tion).


4 Your Options

We offer you cer­tain choices about how we com­mu­ni­cate with you and what infor­ma­tion we col­lect from you. You may choose not to receive mar­ket­ing email com­mu­ni­ca­tions from us by click­ing on the unsub­scribe link in our mar­ket­ing emails, adjust­ing your email pref­er­ences in your pro­file in your SHORELESS Account, or con­tact­ing us as spec­i­fied in the "How To Con­tact Us" sec­tion below.

You also may ask us not to send you other mar­ket­ing com­mu­ni­ca­tions by con­tact­ing us as spec­i­fied in the "How To Con­tact Us" sec­tion below, and we will honor your request. Con­sis­tent with the choices avail­able in the "Infor­ma­tion We Share" sec­tion, you may with­draw your con­sent or object to cer­tain infor­ma­tion shar­ing by select­ing the Pri­vacy Pref­er­ences link below or by con­tact­ing us as indi­cated below.

In addi­tion, as required by law, you may object at any time on legit­i­mate grounds and free of charge to the pro­cess­ing of your per­sonal infor­ma­tion, and we will apply your pref­er­ences going for­ward.

You may also ask us to refrain from shar­ing your per­sonal infor­ma­tion with cer­tain of our affil­i­ates. Please tell us your pref­er­ence by con­tact­ing us as spec­i­fied below.


5 Access and Correction

Sub­ject to applic­a­ble law,

  1. you may obtain a copy of cer­tain per­sonal infor­ma­tion we main­tain about you or update or cor­rect inac­cu­ra­cies in that infor­ma­tion through your SHORELESS Account on https://accounts.shore­less.lim­ited or
  2. you may have the right to obtain access to per­sonal infor­ma­tion we main­tain about you by con­tact­ing us as indi­cated in the "How To Con­tact Us" sec­tion of this Pri­vacy Pol­icy.

To help pro­tect your pri­vacy and main­tain secu­rity, we will take steps to ver­ify your iden­tity before grant­ing you access to the infor­ma­tion. In addi­tion, if you believe that per­sonal infor­ma­tion we main­tain about you is inac­cu­rate, sub­ject to applic­a­ble law, you may have the right to request that we cor­rect or amend the infor­ma­tion by con­tact­ing us as indi­cated below.


6 Non-SHORELESS Places and Services

For your con­ve­nience and infor­ma­tion, our Web­sites and apps may con­tain links to non-SHORELESS places that may be oper­ated by com­pa­nies not affil­i­ated with SHORELESS. These com­pa­nies may have their own pri­vacy poli­cies or notices, which we strongly sug­gest you review. Our ser­vices also may be made avail­able to you through third-party plat­forms (such as providers of app stores) or through other third-party chan­nels.

We can't influ­ence and are not respon­si­ble for the pri­vacy prac­tices of any non-SHORELESS places or ser­vices.


7 Data Transfers

We may trans­fer the per­sonal infor­ma­tion we col­lect about you to coun­tries other than the coun­try in which the infor­ma­tion orig­i­nally was col­lected. Those coun­tries may not have the same data pro­tec­tion laws as the coun­try in which you ini­tially pro­vided the infor­ma­tion.

When we trans­fer your infor­ma­tion to other coun­tries, we will pro­tect that infor­ma­tion as described in this Pri­vacy Pol­icy and in accor­dance with applic­a­ble law. We use con­trac­tual pro­tec­tions for the trans­fer of per­sonal infor­ma­tion among var­i­ous juris­dic­tions (includ­ing, for exam­ple, the Euro­pean Com­mis­sion's stan­dard con­trac­tual clauses).


8 How we protect Personal Information

We main­tain admin­is­tra­tive, tech­ni­cal and phys­i­cal safe­guards designed to pro­tect the per­sonal infor­ma­tion you pro­vide against acci­den­tal, unlaw­ful or unau­tho­rized destruc­tion, loss, alter­ation, access, dis­clo­sure or use. Those safe­guards include:

  1. All of our staff, employ­ees and affil­i­ates ("Asso­ci­ates") are sub­ject to this Pri­vacy Pol­icy and cer­tain codes of con­duct. Under these codes of con­duct, our Asso­ci­ates must fol­low the laws, rules, reg­u­la­tions, court and/or admin­is­tra­tive orders that apply to our busi­ness - includ­ing, specif­i­cally, the legal require­ments and com­pany poli­cies sur­round­ing the pri­vacy of com­mu­ni­ca­tions and the secu­rity and pri­vacy of your records. We take this seri­ously, and any of our Asso­ci­ates who fails to meet the stan­dards we've set in the codes of con­duct is sub­ject to dis­ci­pli­nary and legal action. That includes dis­missal and ter­mi­na­tion of coop­er­a­tion con­tracts.
  2. We've imple­mented tech­nol­ogy and secu­rity fea­tures and strict pol­icy guide­lines to safe­guard the pri­vacy of your Per­sonal Infor­ma­tion. Some exam­ples are:
    • Main­tain­ing and pro­tect­ing the secu­rity of com­puter stor­age and net­work equip­ment, and using our secu­rity pro­ce­dures that require our Asso­ci­ates' user names and pass­words to access sen­si­tive data;
    • Apply­ing encryp­tion or other appro­pri­ate secu­rity con­trols to pro­tect Per­sonal Infor­ma­tion when stored or trans­mit­ted by us;
    • Lim­it­ing access to Per­sonal Infor­ma­tion to only those with jobs requir­ing such access; and
    • Requir­ing caller/online authen­ti­ca­tion before pro­vid­ing Account Infor­ma­tion so that only you or some­one who knows your Account Infor­ma­tion will be able to access or change the infor­ma­tion.
  3. Our affil­i­ates and SHORELESS Busi­ness Part­ners are bound to non-dis­clo­sure agree­ments that ensure your per­sonal infor­ma­tion only being dis­closed to con­duct ser­vices to our request and on our behalf.

Although we strive to keep your Per­sonal Infor­ma­tion secure, no secu­rity mea­sures are per­fect, and we can­not guar­an­tee that your Per­sonal Infor­ma­tion will never be dis­closed in a man­ner incon­sis­tent with this Pri­vacy Pol­icy, for exam­ple as the result of unau­tho­rized acts by third par­ties that vio­late the law or this Pri­vacy Pol­icy, or when Per­sonal Infor­ma­tion is trans­mit­ted to us by unen­crypted or non-obfus­cated com­mu­ni­ca­tion chan­nels that may be inter­cepted and exploited by oth­ers.


9 Updates to our Privacy Policy

This Pri­vacy Pol­icy may be updated peri­od­i­cally and with­out prior notice to you to reflect changes in our Per­sonal infor­ma­tion prac­tices. We will post a promi­nent notice on our Web­sites to notify you of any sig­nif­i­cant changes to our Pri­vacy Pol­icy and indi­cate at the top of the notice when it was most recently updated.


10 How to contact us

If you have any ques­tions or com­ments about this Pri­vacy Notice, or if you would like us to update infor­ma­tion we have about you or your pref­er­ences, please con­tact us by email at pri­vacy@shore­less.lim­ited. You also may write to us at:

Atten­tion: Global Pri­vacy Man­ager
20th Floor, Cen­tral Tower
28 Queen's Road, Cen­tral
Hong Kong SAR