We at SHORELESS Limited, along with our related entities and affiliates (collectively, "SHORELESS"), respect your concerns about privacy. We value your privacy and strive to protect your 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.
Table of Contents
- Information we collect
- Information we don't collect
- How we use the information we obtain
- How we share the information we collect
- Your choices about collection and use of your information
- Access, control and corrections of your information
- Non-SHORELESS places and services
- How we protect Personal Information
- How to contact us
- the SHORELESS websites and web services at shoreless.limited and all its subdomains *.shoreless.limited
It is not applicable to:
- Third Party Products. These are products or services SHORELESS offers to you in order to complement and extend our own Services and Products. Such Third Party Products may be third party software, plugins and add-ons, hosting and cloud storage solutions, third party software licenses, SSL certificates, Domain names, and the like. You should always review the policies of third party products and services to make sure you are comfortable with the ways in which they collect and use your information.
A "cookie" is a text file that websites send to a visitors' computer or other internet-connected device to uniquely identify the visitors' 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.
2.2 Tracking and analytics
We use a number of third party analytics and service providers to help us evaluate our users' use of SHORELESS online-Services and Products, to compile statistical reports on activity, and to improve our content and website performance.
We only use these third party analytics providers on certain areas of our websites, online-Services and Products, and all of them have signed data protection agreements with us that limit the type of personal information they can collect and the purpose for which they can process the information.
In addition, we use our own internal analytics software to provide features and improve our content and performance.
We do not currently respond to your browsers' Do Not Track signal, and we do not permit third parties other than our analytics and service providers to track SHORELESS users' activity over time on our websites, online-Services and Products. We do not track your online browsing activity on other online services over time.
3 Information we collect
3.1 Automatic information collection
When you visit our websites, use our apps, or interact with certain SHORELESS-related online-Services and Products, such as online-tools, widgets or plug-ins, we may collect non-personally-identifying information of the sort that web browsers, Operating Systems and servers typically make available.
The information collected in this manner includes:
- Device characteristics
- Operating system
- Language preferences
- Referring URLs (if provided)
- Information on actions taken
- Dates and times of activity
We also automatically collect potentially personally-identifying information like:
- IP address
- Geographic location
- Unique device identifier
- Browser characteristics
Our primary purpose in collecting any such automatically collected information is to using it in an aggregated, non-personally-indentifying form to better understand, how users interact with our Services and Products, to evaluate how we can constantly improve and provide better services and experiences to our users, and to monitor and protect the security of our Services and Products.
3.2 Information provided by you
If you choose to interact with and use certain Services and Products of SHORELESS, we gather additional personally-identifying information. The amount and type of information that SHORELESS gathers depends on the nature of your interaction.
For example, we ask users of our websites' commenting function, issue tracking system , or other online-tools provided by SHORELESS, to register and login using a personal SHORELESS Account.
In each case, SHORELESS collects such information only as is necessary or appropriate to fulfill the purpose of your interaction with our Services and Products. You can always refuse to supply personally-identifying information, with the caveat that it may prevent you from engaging in certain activities or using certain Services and Products of SHORELESS.
3.2.1 SHORELESS Account
Some online-Services and Products of SHORELESS require user authentication and login. To improve user experience with any such service or product, we offer the SHORELESS Account, our single sign-on solution available at https://accounts.shoreless.limited. It allows you to use any online-Services and Products of SHORELESS that you have been granted access to by using a single username and password.
When you register a SHORELESS Account to interact with SHORELESS Services and Products that require user authentication and login, we will collect and store the following information:
- First name
- Last name
- Preferred language
- Primary email address
- Hashed password
Optionally, we may obtain your social login handles, if you choose to connect your SHORELESS Account to any social login provider such as login with Google, LinkedIn, Facebook, GitHub, Twitter, and/or StackOverflow.
When you interact with any of our online-Services and Products using your SHORELESS Account, we place cookies with session information and your account activity on your computer. Our online-Services and Products use this information to verify that you are logged in and are authorized to use the respective service or product.
3.2.2 Profile information
When you maintain and complete a public user profile in our online-Services and Products, you can optionally share certain personally identifying information.
Such profile information includes:
- Public email address
- Instant messaging IDs and social page links on Skype, LinkedIn, Twitter, Facebook, or WeChat
- Website URL
- Short bio
- Technology expertise and interests
- Organization and role
- Location and timezone
- Spoken language(s)
- Display picture
If you choose to complete this profile information, it may be publicly displayed or shared with team members and/or stakeholders in project groups and software application issue and support queues, until you remove this information from your profile, or cancel your profile within the respective SHORELESS Service or Product and/or your SHORELESS Account.
3.2.3 Billing and payment information
For Services and Products requiring payment, we collect individual and/or business billing and shipping information for invoicing purposes. Such information includes:
- Your name
- Your organisation/company name
- Physical billing/shipping address
- Email address
- Telephone number
If you elect to pay by credit card, SHORELESS may engage a third party to securely process your payment. All payment processing is done through a PCI DSS compliant third party. If you are paying by a credit card, your card details are vaulted through a third party payment gateway. SHORELESS will store an encrypted token along with the last four digits of the credit card and the expiration month and year of the card.
If you elect to pay by direct debit or bank transfer, SHORELESS may additionally collect and store your bank account information.
We may also obtain your tax identification number in circumstances in which you request Services and Products for which it is required.
3.2.4 Contributions and information you post/share on our public websites and online-Services
When you choose to use certain of our online-Services and Products such as our chat or online-support, we collect a record of your communications with us and other third parties that are participating in the communication. SHORELESS Account and usage information including your IP address and browser data may be used for diagnosis, security and service and product optimization.
Please be aware, that when you use our public issue queues, commenting functions or software discussion groups, you cannot revoke permission for SHORELESS to publish and to allow others to have derivative rights to such public content once it is made public.
The content you contribute on our public online-Services and Products is public. SHORELESS loses direct control over such content when it is published on the open internet. You should be aware that it cannot often be removed from public view even if it is removed from the SHORELESS online-services, products and our servers.
This also means that if you post personal information about yourself, you do so at your own risk, including the risk of abandoning any privacy rights you had in such information.
3.2.5 Talents and job application platform
The SHORELESS talents and job application platform allows companies and individuals seeking job opportunities with SHORELESS to submit personally indentifiable information. Such information includes:
- Your name
- Email address
- Affiliated company (where applicable)
- Resume (where applicable)
along with certain optional information including your phone number, a cover letter (where applicable), and any other related information you provide. If you as job seeker choose to apply for a job posting in our talents and job application platform, your application profile can be accessed and reviewed by our human resources department and our project managers looking to hire you.
You as a job seeker may optionally opt-in to have the information we collect on you saved in our internal talents database. This database relies on your personal information. Additionally to the above mentioned information, it collects certain CV-like details and achievements including employment history, technology expertise, and projects you have been worked on. We may use this information for recruiting purposes and to contact you, if we have job opportunities in the future that match your expertise.
4 Information we don't collect
4.1 Sensitive personal information
We do not intentionally collect sensitive personal information, such as social security numbers, genetic data, health information, or religious information. Although SHORELESS never requests or intentionally collects any such sensitive personal information, we realize that you might store this kind of information in your profile, contributions to our Services and Products, or in our hosting and cloud storage products, such as in your managed webserver storage.
If you store any personal information on our servers, you are consenting to our storage of that information on our servers, which currently are located in Hong Kong, Australia, France and Canada.
4.2 Your information stored on our hosting and cloud storage products
We do not intentionally collect information that is stored in your hosting and cloud storage products provided by SHORELESS. Information in your SHORELESS hosting and cloud storage products belongs to you, and you are responsible for it, as well as for making sure that your content complies with our SHORELESS General Terms of Service and any additional terms, policies and agreements that may apply to your product.
SHORELESS employees and affiliates do not access private hosting and cloud storage provided by SHORELESS, unless required to for security or maintenance, or for support reasons, with the consent of you as the hosting and cloud storage information owner.
If your hosting or cloud storage is public, anyone (including us) may view its contents. If you have included private or sensitive information in your public hosting or cloud storage, such as email addresses, that information may be indexed by search engines or used by third parties. In addition, while we do not generally search for content in your hosting or cloud storage, we may automatically scan our servers for certain unlawful contents or security signatures (viruses, malware, and alike).
4.3 Childrens' personal information
We do not knowingly collect personal information from children under the legal age of 16 without prior verifiable parental consent. If we learn that a child under the age of 16 has submitted personally identifiable information online without parental consent, we will take all reasonable measures to delete such information from our databases and servers and to not use such information for any purpose (except where necessary to protect the safety of the child or others).
5 How we use the information we obtain
Generally, the processing of personal information we perform is necessary for the purposes of our business operations and legitimate interests.
For example, we require personally identifying data elements for you to enter into the SHORELESS General Terms of Service agreement or any other legal binding contract and agreement that applies to the Services and Products you request from us. We process those elements on the basis of performing that contract or agreement.
For security purposes, we must keep logs of IP addresses that access our servers, and in order to respond to legal processes or reporting obligations, we are required to keep records of users, clients and transactions related to our Services and Products.
We also may use the information we obtain about you in other ways for which we provide specific notice and ask for your consent at the time of collection.
5.1 Operate, evaluate and constantly improve our business
We use all of the information we collect to provide the Services and Products you request, and to carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
We also are passionate about creating and improving Services and Products that really help our clients now and in future. Monitoring how you use and interact with these Services and Products helps us to understand and anticipate, how they can be enhanced, made more secure, and may be improved to better suit your needs.
For example, we use aggregated statistics and clickstream data to determine usage patterns that tell us how we may tailor our websites, Services and Products to better meet the needs of its users. A common navigation pattern may reveal which additional shortcuts, links, and information you and other users may benefit from in future.
Constantly striving for better Services and Products, we use the information we obtain to
- conduct surveys and research,
- test features in development, pilot phases and live operations,
- analyze the information we have to evaluate and improve products and services,
- develop new products or features,
- conduct audits and troubleshooting activities, and
- determine the effectiveness of our sales, marketing and advertising activities.
5.2 Communicate with you
We use your information to communicate with you about our Services and Products, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
We do not send any promotional or informational emails without your opt-in first. In case you opt in, we use your information to provide you with promotional materials and Newsletters.
5.3 Ensure safety and security
We use the information we obtain to help verify accounts and activity, and to promote safety and security on and off of our Services and Products, such as by investigating suspicious activity or violations of our terms or policies that apply to the respective Services or Products.
We work hard to protect our systems, your SHORELESS Account and personal information using teams of engineers, automated systems, and advanced technology such as encryption and machine learning.
6 How we share the information we collect
We do not share, sell, rent, or trade any personal information we obtain with third parties for their commercial purposes.
6.1 SHORELESS internal use
In order to provide you with the Services and Products you request, we may share information we obtained internally within our family of companies, or with affiliates and third parties.
6.2 Data processing by affiliates and third-party vendors
We work with a limited number of affiliates and third-party vendors we trust and who globally support our business and help us to provide and improve our Services and Products.
With your permission, and for providing you with the Services and Products you request - such as consulting, software development, hosting services, and IT infrastructure management services - we may share personal information with these affiliates and third-party vendors.
- on-site deployment, support, and training,
- customer service (first-level support, client support ticketing),
- payment processing, accounting, reconciliation and collection of claims,
- shipping and delivery,
- technical infrastructure services (e.g. network data transmission, server housing and hardware maintenance),
- reporting and auditing,
- legal advisory,
and other similar services.
When we transfer your data to our affiliates and third-party vendors, we remain responsible for it, apply highest security standards and encryption, and limit the disclosed information to the minimum required by the affiliate or third-party vendor for performing its respective services.
6.3 Aggregated usage statistics
We do share certain aggregated, non-personally identifying information with others about how our users and clients, collectively, use our Services and Products, or how our users and clients respond to our other offerings, such as our trainings, conferences or events.
For example, we may compile statistics on the amount of downloads and usage of software tools provided on our websites. However, we do not sell this information to advertisers or marketers.
6.4 Data processing and disclosure on our clients' behalf
Many of our clients outsource all or a part of their IT management and software development work to us. Through our IT infrastructure, roll-out and IT support business units, we manage the IT needs of 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 these Services and Products, 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 and process and disclose such information only, as is provisioned by the agreement and required for conducting our services.
6.5 New owner
If the ownership or control of all or a part of our Services and Products or their assets changes (including in the event of a reorganization, dissolution or liquidation), we may transfer your information along with the data protection requirements to the new owner.
6.6 Legal requests and compelled disclosure
SHORELESS may disclose personally-identifying information or other information we collect about you to law enforcement in response to a valid legal request (like a search warrant, subpoena, court order, or similar government order). This may include responding to legal requests from jurisdictions outside of Hong Kong SAR where we have a good faith belief that the response is required by law in that jurisdiction, affects clients and users in that jurisdiction, and is consistent with internationally recognized standards.
We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect our property and rights, or those of third parties or the public at large, including as part of investigations; or to prevent death or imminent bodily harm.
In complying with court orders and similar legal processes, SHORELESS strives for transparency. When permitted, we will make a reasonable effort to notify clients and users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.
6.7 Cross-border 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.
7 Your choices about collection and use of your information
We offer you certain choices about how we communicate with you and what information we collect from you.
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 with the caveat that it may prevent you from further engaging in certain activities or using certain Services and Products of SHORELESS.
7.1 Automatic information collection
7.2 Promotional and informational emails and newsletters
You may choose not to receive marketing email communications and newsletters from us by revoking your consent and clicking on the unsubscribe/opt-out link in these emails, adjusting your email preferences in your profile and/or in your SHORELESS Account, or by contacting us as specified in the "How To Contact Us" section below.
Note that even if you opt-out from receiving promotional and informational emails, you may still receive transactional emails from us (for example, emails related to the completion of your SHORELESS Account registration, abandoned cart reminders, correction of user data, password reset requests, notification/alert/reminder emails that you have requested, changes of our terms and policies, and any other similar communications essential to your transactions with SHORELESS and our Services and Products.
8 Access, control and corrections of your information
8.1 Information provided by you
If you're already a client or user of any SHORELESS online-Service or Product, you may access, update, alter, or delete the information provided by you by editing your SHORELESS Account and user profile information or by contacting us as specified in the "How To Contact Us" section below.
You can control the information provided by you by limiting what information is in your profile, by updating out of date information, or by contacting us as specified in the "How To Contact Us" section below.
To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.
8.2 Information usage report request
If you believe that personal information we maintain about you is inaccurate, subject to applicable law, you can always request detailed information about which information we collected about you and on how we use your personally identifiable information.
You can also ask us to correct or amend the information, or revoke your consent in our usage and disclosure of the information by contacting us as specified in the "How To Contact Us" section below.
8.3 Data portability
As our client and user of any SHORELESS Service and Product, you can always take your data with you. You can request an information usage report or copy all of the data we have about you.
8.4 Data retention and deletion
Generally, SHORELESS will retain your personally identifiable and other collected information for as long as you use any of our Services or Products or as needed to provide you with further Services and Products.
We may retain publicly accessible information provided by you indefinitely, unless you delete it or request its deletion. For example, for consistency reasons, we don’t automatically delete your contributions and provided information to publicly accessible Services or Products, after you cancel your SHORELESS Account. This information will be retained indefinitely and deidentified by assigning it to an anonymous account.
If you would like to cancel your SHORELESS Account or delete your user profile information, you may do so in your SHORELESS Account or user profile.
Information we receive about you, including financial transaction data related to purchases made with SHORELESS, may be accessed, processed and retained for an extended period of time as necessary
- to comply with our legal obligations,
- to resolve disputes,
- to enforce our agreements,
- when it is the subject of a legal request or obligation,
- when it is subject to governmental investigation,
- when it is subject to investigations concerning possible violations of our terms or policies,
- or otherwise to prevent harm.
We also may retain information from SHORELESS Accounts disabled for violations of our General Terms of Service for at least a year to prevent repeat abuse or other violations of our terms.
Barring above requirements, we will delete your full profile (within reason) within 90 days. You may contact SHORELESS as specified in the "How To Contact Us" section below to request the erasure of the data we process on the basis of consent within 30 days.
9 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.
10 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:
- 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 SHORELESS Account or user profile information so that only you or someone who knows your SHORELESS Account information will be able to access or change the information.
- Our affiliates and third-party vendors are bound to non-disclosure agreements that ensure your personal information only being disclosed to conduct services to our request and on our behalf.
12 How to contact us
You also may write to us at:SHORELESS Limited
Attention: Global Privacy Manager
Room 2302, 23/F Lee Garden Two
28 Yun Ping Road, Causeway Bay
Hong Kong SAR