Last update: June 27th, 2021
This Policy is incorporated into and is subject to, the Sheetly Terms of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in the Sheetly Terms of Service.
“Customer” means a customer of Sheetly.
“Customer Data“ means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Service.
“Private Data” means any information relating to an identified or identifiable natural person.
“Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to log in.
“Application Area” means the area of the Site that can be accessed only by Users, and where access requires logging in.
“User” means an employee, agent, or representative of a Customer, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.
“Guest” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.
2. THE INFORMATION WE COLLECT ON THE SERVICE:
We collect different types of information from or through the Service. The legal bases for Sheetly’s processing of personal data are primarily that the processing is necessary for providing the Service in accordance with Sheetly’s Terms of Service and that the processing is carried out in Sheetly’s legitimate interests, which are further explained in the section “How We Use the Information We Collect” of this Policy. We may also process data upon your consent, asking for it as appropriate.
2.1 USER-PROVIDED INFORMATION
When you use the Service, as a User or as a Guest, you may provide, and we may collect Private Data. Examples of Private Data include name, email address, mailing address, mobile phone number, and a credit card or other billing information. Private Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Private Data in various ways on the Service. For example, when you register for an Account, use the Service, post Customer Data, interact with other users of the Service through a communication or messaging capabilities, or send us customer service-related requests.
2.2 INFORMATION COLLECTED BY CUSTOMERS
A Customer or User may store or upload into the Service Customer Data. Sheetly has no direct relationship with the individuals whose Private Data it hosts as part of Customer Data. Each Customer is responsible for providing notice to its customers and third persons concerning the purpose for which Customer collects their Private Data and how this Private Data is processed in or through the Service as part of Customer Data.
2.3 “AUTOMATICALLY COLLECTED" INFORMATION
When a User or Guest uses the Service, we may automatically record certain information from the User’s or Guest’s device by using various types of technology, including cookies, “clear gifs" or “web beacons.” This “automatically collected" information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User or Guest views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Guest or User’s interaction with email messages, such as whether the Guest or User opens, clicks on, or forwards a message. This information is gathered from all Users and Visitors.
2.4 INTEGRATED SERVICES
2.5 INFORMATION FROM OTHER SOURCES
We may obtain information, including Private Data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Private Data that we collect through the Service, we will treat the combined information as Private Data in accordance with this Policy.
3. HOW WE USE THE INFORMATION WE COLLECT
We use the information that we collect in a variety of ways in providing the Service and operating our business, including the following:
We use the information – other than Customer Data - to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Customer Data solely in accordance with the directions provided by the applicable Customer or User.
We use the information to understand and analyze the usage trends and preferences of our Guests and Users, to improve the Service, and to develop new products, services, feature, and functionality. Should this purpose require Sheetly to process Customer Data, then the data will only be used in anonymized or aggregated form.
We may use a Guest’s or User’s email address or other information – other than Customer Data – to contact that Guest or User (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Customer Data or Private Data posted on the Service or (ii) with updates on promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”
3.4 COOKIES AND TRACKING TECHNOLOGIES
We use automatically-collected information and other information collected on the Service through cookies and similar technologies to (i) personalize our Service, such as remembering a User’s or Guest’s information so that the User or Guest will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as the total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.
We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify guest preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Guests or Users.
4. TO WHOM WE DISCLOSE INFORMATION
Except as described in this Policy, we will not intentionally disclose the Private Data or Customer Data that we collect or store on the Service to third parties without the consent of the applicable Guest, User or Customer. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
4.1 UNRESTRICTED INFORMATION
Any information that you voluntarily choose to include in a Public Area of the Service, such as a public profile page, will be available to any Guest or User who has access to that content.
4.2 SERVICE PROVIDERS
We work with third-party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Private Data or Customer Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
4.3 NON PERSONALLY IDENTIFIABLE INFORMATION
We may 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 our Customers’, Users’ and Guests’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.
4.4 LAW ENFORCEMENT, LEGAL PROCESS AND COMPLIANCE
We may disclose Private Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
We also reserve the right to disclose Private Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
4.5 CHANGE OF OWNERSHIP
5. YOUR CHOICES
5.1 ACCESS, CORRECTION, DELETION
We respect your privacy rights and provide you with reasonable access to the Private Data that you may have provided through your use of the Services. If you wish to access or amend any other Private Data we hold about you, or to request that we delete or transfer any information about you that we have obtained from an Integrated Service, you may contact us as set forth in the “How to Contact Us” section. At your request, we will have any reference to you deleted or blocked in our database.
You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, the satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may decline to share certain Private Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.
At any time, you may object to the processing of your Private Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact Sheetly’s Data Protection Officer at dpo@Sheetly.io. You also have a right to lodge a complaint with data protection authorities.
5.2 NAVIGATION INFORMATION
You may opt-out from the collection of navigation information about your visit to the Site Google Analytics by using the Google Analytics Opt-out feature.
5.3 OPTING OUT FROM COMMERCIAL COMMUNICATIONS
If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “How to Contact Us” section.
Users are able to view and modify settings relating to the nature and frequency of promotional communications that they receive from us by accessing the “Account functionality” tab on the Service.
Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.
6. THIRD-PARTY SERVICES
The Service may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
7. INTEREST-BASED ADVERTISING
Interest-based advertising is the collection of data from different sources and across different platforms in order to predict an individual’s preferences or interest and to deliver to that individual, or his/her computer, smartphone or tablet, advertising based on his/her assumed preference or interest inferred from the collection of data pertaining to that individual or others who may have a similar profile or similar interests.
We work with a variety of third parties to attempt to understand the profiles of the individuals who are most likely to be interested in the Sheetly products or services so that we can send them promotional emails, or serve our advertisements to them on the websites and mobile apps of other entities.
These third parties include (a) advertising networks, which collect information about a person’s interests when that person views or interacts with one of their advertisements; (2) attribution partners, which measure the effectiveness of certain advertisements; and (3) business partners, which collect information when a person views or interacts with one of their advertisements.
In collaboration with these third parties, we collect information about our customers, prospects and other individuals over time and across different platforms when they use these platforms or interact with them.
Individuals may submit information directly on our Sites or on platforms run by third parties, or by interacting with us, our advertisements, or emails they receive from us or from third parties. We may use special tools that are commonly used for this purpose, such as cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar technologies. We may have access to databases of information collected by our business partners.
The information we or third party collect enables us to learn what purchases the person made, what ads or content the person sees, on which ads or links the person clicks, and other actions that the person takes on our Sites, or in response to our emails, or when visiting or using third parties’ platforms.
We, or the third parties with which we work, use the information collected as described above to understand the various activities and behaviours of our customers, Site visitors and others. We, or these third parties, do this for many reasons, including: to recognize new or past visitors to our Sites; to present more personalized content; to provide more useful and relevant ads - for example, if we know what ads you are shown we can try not to show you the same ones repeatedly; to identify visitors across devices, sales channels, third party websites and Sites, or to display or send personalized or targeted ads and other custom content that is more focused on a person’s perceived interest in products or services similar to those that we offer.
Our interest-based ads may be served to you in emails or on third-party platforms. We may serve these ads about our products or services or send commercial communications directly ourselves or through these third parties.
Guests may opt out of receiving interest-based advertising by advertising networks that may be delivered to them on our platform and other websites by visiting the following websites: http://www.aboutads.info/consumers; and http://www.networkadvertising.org. These features will opt a Guest out of many – but not all - of the interest-based advertising activities in which we or third parties engaged.
8. DATA SECURITY
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Private Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Private Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through the public internet, and we also employ application-layer security features to further anonymize Private Data.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Private Data has been compromised, please contact us as set forth in the “How to Contact Us” section.
If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
9. DATA RETENTION
We only retain the Private Data collected from a User for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfil the purposes for which we have initially collected it unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
the contents of closed accounts are deleted within 3 months of the date of closure;
backups are kept for 3 months;
Although we may allow you to adjust your privacy settings to limit access to certain Private Data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.
11. DATA TRANSFER
The Service is hosted in the United States or Ireland. EU customers’ databases will be hosted in Sheetly’s EU datacenter located in Dublin, Ireland. Regardless of the database being hosted in the EU, if you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you may be transferring your Customer Data and Private Data outside of those regions to the United States for storage and processing by our service providers listed in the Sheetly Terms of Service. We will comply with GDPR requirements providing adequate protection for the transfer of personal information from Europe to the U.S. Also, we may transfer your data to the U.S., the EEA, or other countries or regions deemed by the European Commission to provide adequate protection of personal data in connection with storage and processing of data, fulfilling your requests, and operating the Service.
12. DATA CONTROLLER AND DATA PROCESSOR
Sheetly does not own, control or direct the use of any of the Customer Data stored or processed by a Customer or User via the Service. Only the Customer or Users are entitled to access, retrieve and direct the use of such Customer Data. Sheetly is largely unaware of what Customer Data is actually being stored or made available by a Customer or User to the Service and does not directly access such Customer Data except as authorized by the Customer, or as necessary to provide Services to the Customer and its Users.
The Customer or the User is the data controller under the Regulation for any Customer Data containing Private Data, meaning that such party controls the manner such Private Data is collected and used as well as the determination of the purposes and means of the processing of such Private Data.
Sheetly is not responsible for the content of the Private Data contained in the Customer Data or other information stored on its servers (or its subcontractors’ servers) at the discretion of the Customer or User nor is Sheetly responsible for the manner in which the Customer or User collects, handles disclosure, distributes or otherwise processes such information.
13. CHANGES AND UPDATES TO THIS POLICY
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 Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
14. HOW TO CONTACT US
Please contact us with any questions or comments about this Policy, your Private Data, our use and disclosure practices, or your consent choices by email at firstname.lastname@example.org. If you have any concerns or complaints about this Policy or your Private Data, you may contact Sheetly’s Data Protection Officer by email at email@example.com.