SHORELESS Pri­vacy Pol­icy

What Infor­ma­tion SHORELESS col­lects, and what we do with it

Last Change: May, 25th 2018

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.

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.

Table of Contents

  1. Scope of this Pri­vacy Pol­icy
  2. Our use of cook­ies and track­ing
    1. Cook­ies
    2. Track­ing and ana­lyt­ics
  3. Infor­ma­tion we col­lect
    1. Auto­matic infor­ma­tion col­lec­tion
    2. Infor­ma­tion pro­vided by you
      1. SHORELESS Account
      2. Pro­file infor­ma­tion
      3. Billing and pay­ment infor­ma­tion
      4. Con­tri­bu­tions and infor­ma­tion you post/share on our pub­lic web­sites and online-Ser­vices
      5. Tal­ents and job appli­ca­tion plat­form
  4. Infor­ma­tion we don't col­lect
    1. Sen­si­tive per­sonal infor­ma­tion
    2. Your infor­ma­tion stored on our host­ing and cloud stor­age prod­ucts
    3. Chil­drens' per­sonal infor­ma­tion
  5. How we use the infor­ma­tion we obtain
    1. Oper­ate, eval­u­ate and con­stantly improve our busi­ness
    2. Com­mu­ni­cate with you
    3. Ensure safety and secu­rity
  6. How we share the infor­ma­tion we col­lect
    1. SHORELESS inter­nal use
    2. Data pro­cess­ing by affil­i­ates and third-party ven­dors
    3. Aggre­gated usage sta­tis­tics
    4. Data pro­cess­ing and dis­clo­sure on our clients' behalf
    5. New owner
    6. Legal requests and com­pelled dis­clo­sure
    7. Cross-bor­der data trans­fers
  7. Your choices about col­lec­tion and use of your infor­ma­tion
    1. Auto­matic infor­ma­tion col­lec­tion
    2. Pro­mo­tional and infor­ma­tional emails and newslet­ters
  8. Access, con­trol and cor­rec­tions of your infor­ma­tion
    1. Infor­ma­tion pro­vided by you
    2. Infor­ma­tion usage report request
    3. Data porta­bil­ity
    4. Data reten­tion and dele­tion
  9. Non-SHORELESS places and ser­vices
  10. How we pro­tect Per­sonal Infor­ma­tion
  11. Updates to our Pri­vacy Pol­icy
  12. How to con­tact us
 

1 Scope of this Privacy Policy

This Pri­vacy Pol­icy applies to all SHORELESS Ser­vices and Prod­ucts made avail­able to you, that ref­er­ence to this Pri­vacy Pol­icy, which explic­itly includes:

  • the SHORELESS web­sites and web ser­vices at shore­less.lim­ited and all its sub­do­mains *.shore­less.lim­ited

It is not applic­a­ble to:

  • Ser­vices and Prod­ucts for which a sep­a­rate pri­vacy pol­icy is pro­vided.
  • 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.
 

2 Our use of cookies and tracking

 

2.1 Cookies

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.

SHORELESS uses cook­ies and web bea­cons to make inter­ac­tions with our online-Ser­vices and Prod­ucts easy and mean­ing­ful. We use cook­ies and web bea­cons to keep you logged in, remem­ber your pref­er­ences, and pro­vide infor­ma­tion for future improve­ments of our Ser­vices and Prod­ucts.

We also use cook­ies to iden­tify a device for secu­rity rea­sons. By using our web­sites or online-Ser­vices and Prod­ucts, you agree that we can place these types of cook­ies on your com­puter or device. If you dis­able your browser or devices' abil­ity to accept cook­ies, you will not be able to log in or use cer­tain of our online-Ser­vices and Prod­ucts.

 

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

Except for pro­tect­ing against, to iden­tify and to pre­vent fraud and other crim­i­nal activ­ity, claims and other lia­bil­i­ties, and to com­ply with applic­a­ble legal require­ments and our inter­ests and poli­cies as set forth in this Pri­vacy Pol­icy, we do not dis­close or use such infor­ma­tion to iden­tify our users.

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:

  • User­name
  • 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
  • Loca­tion
  • Email address
  • Birth­date
  • 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.

We do not dis­close per­sonal infor­ma­tion out­side SHORELESS, except in the sit­u­a­tions listed in this Pri­vacy Pol­icy.

 

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.

Our affil­i­ates and third-party ven­dors have agreed to adhere to strict con­fi­den­tial­ity oblig­a­tions in a way that is con­sis­tent with this Pri­vacy Pol­icy restric­tions. They process the infor­ma­tion on our behalf for per­form­ing ser­vices such as

  • 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.

Infor­ma­tion col­lected within the Euro­pean Eco­nomic Area (“EEA”) may, for exam­ple, be trans­ferred to coun­tries out­side of the EEA for the pur­poses as described in this Pri­vacy Pol­icy.

When we trans­fer your infor­ma­tion to other coun­tries, we will pro­tect that infor­ma­tion as described in this Pri­vacy Pol­icy and uti­lize stan­dard con­tract clauses approved by the Euro­pean Com­mis­sion, adopt other means under Euro­pean Union law, and obtain your con­sent to legit­imize data trans­fers from the EEA to the Hong Kong SAR and other coun­tries.

 

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:

  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 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.
  3. 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.

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.

 

11 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 Pri­vacy Pol­icy when it was most recently updated.

 

12 How to contact us

If you have any ques­tions or com­ments about this Pri­vacy Pol­icy, how we col­lect, use and share your infor­ma­tion, 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:

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