Privacy Policy

ShuffleLabs U.S. Privacy Statement

Your privacy is important to us so we have developed this Privacy Statement that outlines our privacy practice on how we process, collect, use and share your personal information as well as your privacy rights under certain privacy laws. This Privacy Statement (“Privacy Statement”) applies to ShuffleLabs, Inc. and ShuffleExchange™.

Overview of Our Privacy Practice

Information We Collect About You

We collect your personal information directly from you through your interactions, use, and experiences with our website, products and services. We also obtain your information indirectly from our Business Partner and third-party sources. For more information about the types and sources of information we collect about you refer to: Information We Collect About You.

How We Use and Share Your Information

We use your personal information to provide you with our products and services, improve our products and services, tailor your customer experience with ShuffleLabs, personalize our products and services and make recommendations to you, advertise and market to you, and to comply with applicable laws. Also, we use your information to help improve the safety of our website, products and services, which includes detecting, preventing and responding to fraud and security risks that could harm you or ShuffleLabs. We may share your personal information with our affiliated companies, and Business Partners to perform work for us, including completing any transaction, providing you with the latest information about our products and services, offering you our latest promotions.

For more information refer to How We Use and Share Your Information.

Our Use of Cookies and Other Technologies

ShuffleLabs’ websites, online services, interactive applications, email messages, and advertisements may use cookies and similar technologies to help us tailor your experience, better understand your preferences, tell us which parts of our websites you have visited, facilitate and measure the effectiveness of our interest-based advertisements and web searches. We also use web beacons to help deliver cookies and gather usage and performance data. You have choices about how ShuffleLabs and our Business Partner reach you. For more information refer to Our Use of Cookies and Other Technologies.

Accessing, Deleting and Updating Your Information and Contact Us

You can exercise your Consumer Privacy Rights in relation to your personal information by sending an email to privacy@shufflelabs.com. For more information, refer to Your Consumer Privacy Rights.

If you have a privacy question (other than in connection with marketing), concern or complaint, please contact us at privacy@shufflelabs.com.

Special Considerations for California Residents

As a California resident, you have certain consumer privacy rights which you can learn about and exercise as described here. If you want to learn more about the categories of the personal information we collect about you and how we share your personal information with our Business Partners, click here. We do not “sell” your personal information to any Business Partners as currently defined under the California Consumer Protection Act. You have choices about how ShuffleLabs reaches you with marketing offers and about other uses of your information. For more information about your choices refer to Your Marketing Choices and Our Use of Cookies and Other Technologies.

Business Partner

Means any contractor, supplier, service provider, debit or credit card processor with whom we have a business relationship to provide you with our offers, products, services, process your payment, better predict and deliver content and marketing offers that may interest you.

Changes to This Privacy Statement

• Feedback from our customers, regulators, industry or other stakeholders.
• Changes in our privacy practices, products or services.
• Changes in applicable privacy laws.

If there are material changes to the Privacy Statement, we will revise the “last updated” date at the bottom of the statement. We encourage you to periodically review this Privacy Statement to learn how ShuffleLabs is protecting your information.

Information We Collect

The types of information we collect about you depends on your use of our products, services and the ways that you interact with us. This may include information about:

• How you use or visit websites, accounts with ShuffleLabs or applications.
• How you use services and products and interact with those services or products.
• Contact, billing and other information you provide.
• Improve and develop our products and services.
• Personalize our products and services and make recommendations.
• Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you with relevant offers.

We also obtain information from third-party sources. We protect information obtained from third parties according to the privacy practices as described in this Privacy Statement. These third-party sources vary over time and may include:

• Data brokers from which we purchase demographic data to supplement the information we have collected about you.
• Communication services, including email providers and social networks, when you give permission to access your information on such third-party services or networks.
• Partners with which we offer co-branded products or services or engage in joint marketing activities.
• Publicly available sources, such as open government databases.

The personal information we may collect can include the following:

• Contact details such as your name, email address, home address, contact telephone numbers.
• Employment information such as your job title and other business or company information.
• Credentials such as your passwords, password hints, and similar security information used for authentication and MyAccount access.
• Demographic information such as your age, gender, country, interests, and preferences;
• Web form information you provide in our web forms (forms that you choose to complete will indicate whether the information requested is mandatory or voluntary);
• Payment information to process payments, such as your payment instrument number (such as a credit card number) and the security code associated with your payment instrument.
• Account history information related to the products or services you purchase, and the activities associated with your account.
• Cookie and tracking information such as IP address, device identifier, location data, browser type and language, access times, the Uniform Resource Locator (URL), other unique identifiers and other technical data that may uniquely identify your device, system or browser.
• Browse history information about the websites the websites you visit.
• Error reports and performance information of the products and any problems you experience, including error reports.
• Troubleshooting and help information when you contact ShuffleLabs for technical support or customer support services, phone conversations or chat sessions with our representatives may be monitored and recorded.
• Content consumption information about media content (e.g. TV, apps and games) you access through our products.
• Feedback and ratings information you provide to us such as customer survey feedback and product reviews you write.
• Configuration Data including how you use the Services (including those applications, clouds, and other sites you connect to with the Services);

Feature Use including how you interact with Services.

How We Use and Share Your Information

• Deliver and maintain our products and services and related infrastructure.
• Establish and maintain your account.
• Measure credit and payment risk.
• Provide account related services and information.
• Help you with customer service and technical support issues or questions.
• Conduct statistical analysis.
• Help us improve or personalize our products and services.
• Better predict content and marketing offers that may interest you, which includes sending promotional communications, targeting advertising, and presenting you with relevant offers.
• Authenticate you.
• Detect and prevent fraud.
• Manage and protect our networks, services and customers.
• Meet our legal obligations and doing research.
• Your Consumer Privacy Rights
• You may have the following consumer privacy rights under applicable state laws, including California privacy laws:
• Right to Know: you may have the right to request information about the personal information we have collected about you and for what purpose.
• Right to Access: you may have the right to request information about how we process your personal information and to obtain a copy of that personal information.
• Right to Portability: you may have the right to receive your personal information, in a structured, commonly used and machine-readable format and to have that information transmitted to another organization in certain circumstances.
• Right to Deletion: you may have the right to request the deletion of your personal information that we have collected from you.

Right to be free from discrimination: ShuffleLabs will not discriminate against you for exercising your consumer privacy rights.

Submitting a Request

If you have any questions about the type of personal information we hold about you or if you wish to request deletion of personal information we may hold about you, or exercise any other consumer privacy right as set out above, contact us by sending a written request to privacy@shuffleLabs.com.

Your Marketing Choices

You may choose to receive or not receive marketing communications from ShuffleLabs by indicating your preferences. Opportunities to select your preferences include the following:

You can click “unsubscribe” in any marketing email communications we send you, or

You can send us an email at privacy@shufflelabs.com.

Any marketing by ShuffleLabs, or any third-parties on behalf of ShuffleLabs, will be conducted in accordance with applicable laws and include (where applicable) methods to allow you to express your preferences (including being removed from our advertising and marketing lists as set out above).

How We Secure Your Information

We use appropriate technical, organizational and physical data security safeguards to help protect against unauthorized access to, use or disclosure of information we collect, use or store. The ways we do this include:

• Using encryption when collecting or transferring sensitive information, such as credit card details.
• Design our data security safeguards to ensure the ongoing security, integrity, availability and resilience of processing systems and services.
• Limiting physical access to our premises.
• Limiting access to the information we collect about you.
• Ensuring that our Business Partners have appropriate technical and organizational security measures to keep your personal information protected.
• As required by law, destroying or de-identifying personal information.

We encourage you to keep any passwords you use confidential and to be careful to avoid “phishing” scams where someone may send you an email that appears to be from ShuffleLabs asking for your personal information. ShuffleLabs will not request your ID or password through email.

Collection and Use of Children’s Information

We understand the importance of taking extra precautions to protect the privacy and safety of children using our products, services and our websites. Children under the age of 13 or equivalent minimum age in the relevant jurisdiction, must not share their personal information unless their parent or guardian provided verifiable consent. If at any time a parent or guardian needs to access or delete data associated with their child’s or guardian’s account, they may contact us through one of the options provided in this Privacy Statement.

Links to Third-Party Websites and Services

We may sometimes provide links to other websites, which if you click on them may collect personal information about you and direct you to those websites. The information practices of those third-party websites linked to our website are covered by the third party’s own privacy statements and we encourage you to read those.

Contact Us

If you would like to exercise Your Consumer Privacy Rights as described in this Privacy Statement, have a privacy question, concern or complaint, please contact us at privacy@shufflelabs.com.

Updated: August 1, 2020