At SHACK15, we know that you care about how your personal information is used and shared, and that is why we are committed to respecting your privacy and to helping protect the security of your information. In this Privacy Policy, we describe the information that we collect about you on our websites, including shack15.com and news.shack15.com, and how we use and disclose that information.

By visiting the Site or using any of our services available on our Site, you agree that your information will be handled as described in this Policy.

Your use of our Site, and any dispute over privacy, is subject to this Policy and the terms of use of the Site, including its applicable limitations on damages and the resolution of disputes. The Terms of Use are incorporated by reference into this Policy.

What information do we collect about you and why?

We collect information about you directly from you, automatically through your use of the Site or our services, and through third parties.

We also collect data about your use of our Site automatically according to our Cookie Statement.

Information we collect directly from you

We collect information from you when you request information from us or otherwise interact with our Site and our services. The type of information that we collect from you depends on your particular interaction with our Site and may include, without limitation, your name, address, and email address, and any other information that you choose to provide to us.

Information we collect automatically

We and our third party service providers automatically collect information about you through the use of cookies and other tracking technologies (collectively, “cookies”), including:

• Details of your visits to our Site including, but not limited to, traffic data, location data, weblogs and other communication data, search activities as well as the page, content, software or resources that you access.

• Your IP address, web addresses of the sites you arrive from and go to next and information about your connection, including your device’s browser, operating system, platform type and Internet connection speed. We use this information for operational and performance measurement purposes and to regionalize certain contents of the Site.

• Details of transactions and orders, your history of correspondence with us, quote requests or inquiries or when you contact customer service or technical support.

Currently our Site does not recognize browser requests not to be tracked. You may adjust your browser settings so as not to accept cookies. Please see our Cookie Statement for additional information.

Information we collect about you from third parties

We may also collect data from third parties we use to publish our advertisements or to analyse your interest in our Site, such as Google Adwords, Google Analytics and Linkedin.

How we use your information

Information about our customers is an integral part of our business. We use your information, including your personal information, for the following purposes:

• To provide our Site and services to you, to facilitate the features on our Site, to communicate with you about your use of our Site and Services, to respond to your inquiries, to manage your account, to send you information that you have requested, and for other customer service purposes.

• For marketing and advertising purposes. For example, as permitted by applicable law, we may occasionally contact you by e-mail, postal mail, or telephone to provide you with information about goods or services that might be of interest to you.

• To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Site or our Services.

• To better understand how users access and use our Site and services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes.

When we disclose your information

We do not share your information with non-affiliated third parties for their own marketing purposes. We do share your information as follows:

• To Our Affiliates: As permitted by applicable law, we may share your personal information with our affiliated entities. Those entities may market their products and services to you, but their use of your personal information will be governed by this privacy policy.

• Sales Channel Partners and Distributors: We may provide information about you to carefully screened entities that work on our behalf, such as our Marketing services suppliers, newsletter distributors or other service partners, to market SHACK15 services. Only trusted companies who require the use of said information for business purposes are given access to it.

We also may share your information in the following circumstances:

• Business Transfers: If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company. We also may transfer our rights under any customer agreement we have with you.

• In Response to Legal Process: We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

• To Protect Us and Others: We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved.

• Aggregate and De-Identified Information: We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

• Legal Purposes: To enforce our Terms of Use; for example, to protect the security of our Site, as required by law or when we believe that disclosure is necessary to protect our rights.

Legal Basis for Processing

We have legal basis to collect, use and share your information. You also have choices about our use of your information as explained further below. We will only collect and process your information when we have legal basis to do so. Legal basis includes consent (where you have given consent), contract (where processing is necessary to fulfil contractual obligations (e.g. to provide you with the Services you have purchased)) and legitimate interest. If you have any questions about the legal basis we use to process your information, please contact us at info@shack15.com.

Data Retention

We retain your information as long as we have a legitimate business interest to process it or as long as you have not withdrawn your consent. This includes data you or others provided to us and data generated or inferred from your use of our Site.

Security

SHACK15 takes security of all data, especially your personal information, seriously. We have done our best to protect your information from any unauthorised access or loss with implemented security features and procedures. You should however be aware that the transmission of information via the Internet is never completely secure. You should also take necessary steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Transfers to countries that do not provide adequate level of protection

SHACK15 operates globally and information that we collect from or about you within the European Economic Area (“EEA”) may be transferred across international borders and to countries outside of the EEA that do not have laws providing an adequate level of data protection. We as the Data Controller (or Data Exporter) will do our best to ensure that your information is protected no matter where it is transferred to. To ensure adequate protection we enter into Data Processing Agreements with our suppliers processing your information outside of the EEA. When necessary we utilise standard contract clauses approved by the European Commission or rely on other legally-provided mechanisms (such as the EU-US or Swiss-US Privacy Shield) to ensure the adequate protection of your information.

Opting out of outreach from SHACK15

We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail or by contacting us at info@shack15.com. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any services you have requested or received from us.

Your rights as a data subject

You as a data subject have many possibilities to impact how your personal information is being processed. You can:

• Request access to your information we process

• Withdraw your consent if our use of your information is based on consent

• Request for your information to be deleted or for you to be forgotten (right to erasure)

• Request us to correct or change your information. As a customer you may also do this by logging in to your account.

• Limit, restrict or object to our use of your information

• Access your information and/or receive it in a machine readable form

• Subject to applicable law lodge a complaint with your local data protection authority

Please note that if you request us to remove your information, we may retain some of the information for specific reasons, such as to resolve disputes, troubleshoot problems, and as required by law. Furthermore, some information is never completely removed from our databases because of technical constraints and the fact that we regularly back up our systems. Therefore, not all of your personal information will ever be completely removed from our databases.

Links

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check their policies before you submit any personal data.

Identity and contact details of the Data Controller

The Data Controller of your information submitted through this Site is:

• Meltwater Global Headquarters
• 225 Bush Street, Suite 1000
• San Francisco, CA 94104

If you have any questions about this policy or the use of your personal information, you are always welcome to contact us at info@shack15.com. You will also reach our Data Protection Officer at the same address.

Changes to the Privacy Policy

We may change this Privacy Policy from time to time due to changed or updated legislation and/or business standards. All changes to this Privacy Policy are posted on this page and we encourage you to review our Privacy Policy regularly to stay informed.