By accessing, visiting or using our websites https://www.shyft.network and https://id.shyft.network (collectively the “Website”), contacting us or agreeing to receive emails from Network, you accept the terms and conditions of this Policy.
This Policy does not extend to websites operated by third parties. Network is therefore not liable for their privacy policies, procedures and practices.
Collection of Information
We collect your personal information in several ways, including when you enter information on our Website, register for an account, contact us by telephone or by email, post on our social media accounts, etc. Depending on the circumstances, personal information may include your first name, middle name, last name, gender, email address, mailing address, phone number, photo identification, occupation, date of birth, password. If you choose to withhold any personal information requested by us, it may not be possible for you to gain access to certain parts of the Website.
The legal bases for our processing of personal information are primarily that the processing is necessary for providing the Website and that the processing is carried out in our legitimate interests, which are further explained in the “Use and Communication of Personal Information” section. We may also process personal information upon your consent, asking for it as appropriate.
Use and Communication of Personal Information
We take steps designed to ensure that only those employees who need access to your personal information to fulfill their employment duties will have access to it. We use and disclose your personal information mainly:
- to operate, maintain, enhance and provide all features of the Website, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Website;
- to understand and analyze the usage trends and preferences of our users, to improve the Website, and to develop new products, services, feature, and functionality;
- to send you communications subject to applicable laws; or
- for any other purposes authorized or required by law.
When we disclose your personal information to third parties, we take reasonable measures to ensure that the rules set forth in this Policy are complied with and these third parties provide sufficient guarantees to implement appropriate technical and organisational measures.
In the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of Network, in whole or in part, your personal information may be transferred as part of the transaction.
By providing your personal information, you agree that we may collect and use this information for the purposes of: (a) validating your identity and risk profile, (b) creating a verification profile using your identity and risk profile (“your Verification”) on our blockchain network (the “Ecosystem”); (c) assigning a reputation score to your Verification (“your Reputation”); (d) tracking the number of times your Verification has been re-verified on the Ecosystem (“your Verification Count”); (e) disclosing your Verification, your Reputation, and your Verification Count to registered application providers on the Ecosystem; (f) creating a personalized online account to purchase our cryptocurrency tokens that can be used in the Ecosystem; (g) allowing us to administer that account; (h) only upon your further explicit consent, transmitting your personal information which served as the source of your Verification to application providers on the Ecosystem; and (i) allowing us to conduct analytics on a non-identifiable basis, the results of such analytics not to be shared with third parties without your further explicit consent.
We may finally make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding your interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Website.
Retention of Personal Information
Your personal information may be stored and processed in any country where we have facilities or in which we engage third party service providers. By using the Website, you consent to the transfer of information to countries outside your country of residence, which may have different data protection rules than in your country. Such information is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this Policy and, if applicable, we will comply with the General Data Protection Regulation (“GDPR”) requirements providing adequate protection for the transfer of personal information from the EU/EEA to a third country.
Network has implemented various physical, administrative and technical safeguards designed to protect the confidentiality and security of personal information under our control. However, no security measures are absolute or wholly guaranteed. You agree to be responsible for all activities conducted through your account on the Website and your password, whether conducted by you or by third parties. If you believe personal information has been compromised, please contact us as set forth in the “Contact” section.
We will only keep your personal information for as long as reasonably necessary to fulfill the relevant purposes set out in this Policy and in order to comply with our legal and regulatory obligations. If you would like further information regarding the periods for which your personal information will be kept, please contact us as set forth in the “Contact” section.
Rights Regarding Personal Information
Under certain circumstances and in accordance with EU/EEA or other applicable data protection laws (including the GDPR), an individual has the following rights:
- Access: entitled to ask if we are processing information and, if we are, request access to personal information. This enables the individual to receive a copy of the personal information we hold and certain other information about it;
- Correction: entitled to request that any incomplete or inaccurate personal information we hold is corrected;
- Erasure: entitled to ask us to delete or remove personal information in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal information is required for compliance with law or in connection with claims;
- Restriction: entitled to ask us to suspend the processing of certain of personal information, for example to establish its accuracy or the reason for processing it;
- Transfer: request the transfer certain of personal information to another party;
- Objection: one may challenge when we are processing personal information based on a legitimate interest (or those of a third party) or for direct marketing purposes. However, we may be entitled to continue processing information;
- Automated decisions: contest any automated decision made where this has a legal or similar significant effect and ask for it to be reconsidered.
- Consent: where we are processing personal information with consent, withdrawal of consent.
Individuals also have a right to lodge a complaint with a data protection supervisory authority, in particular in the country/province/state where you are habitually resident and where we are based or where an alleged infringement of data protection law has taken place.
To exercise any of these rights, please contact us as set forth in the “Contact” section.
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Website, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Website after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
The Website is not directed to children under the age of 16, and we do not knowingly collect personal information from children under the age of 16 without obtaining parental consent. If you are under 16 years of age, then please do not use or access the Website at any time or in any manner. If we learn that personal information has been collected via the Website from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 16 years of age has provided personal information, then you may alert us as set forth in the “Contact” section and request that we delete that child’s personal information from our systems.
If you have any questions or comments about this Policy or your personal information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices with respect to any service providers, our Privacy Officer can be reached by email using the following contact information: firstname.lastname@example.org
Last Update: April 24, 2019