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Data Protection and Privacy Policy Effective Date: 04/30/2021

Introduction

SHO is committed to protecting your privacy. This Privacy Policy applies to www.sho-ai.com and SHO (mobile application), owned and operated by SHO Technologies Inc. (collectively as "SHO Technology", "We", "Us", "Our") This Policy details the steps we take to protect your personal information when you use our website and software applications. This Privacy Policy describes how SHO Technology collects, uses, shares and secures the personal information you provide. It also describes your choices regarding use, access and correction of your personal information. By accessing our websites, you are consenting to the information collection and use practices described in this privacy statement. The use of information collected through our service shall be limited to the purpose of providing the service for which you have engaged SHO.

Your Permission

By using SHO products, including SHO’s web and Mobile Apps and cloud services, you give SHO permission to collect, process, and store data as described in this Data Protection and Privacy Notice. Your information, including personal data, may be transferred to the United States and processed and stored there. Your information, including personal data, may also be transferred and processed in other countries where SHO operates. These countries may not have privacy laws similar to or as comprehensive as the laws where you reside and/or are a citizen. By using SHO’s Services, or by accessing its Site, you explicitly consent to this transferring, processing, and storage of your information, including personal data.

As part of delivering our service to you, your information, including personal data, may be transferred and shared with third parties, including our affiliates. By using SHO products, you give SHO permission to share your data with these third parties.

Our collection of information

SHO may collect information about how you use our services (including our websites and applications) by using cookies and similar technologies, and our servers may collect similar information when you are logged in to the website or application. Depending on the website or application, this information may be anonymous or it may be associated with you. The personal information we collect may include:

  • contact details, such as your name, title, company/organization name, email address, telephone and fax numbers, physical address, etc;
  • information about your company, and job function;
  • your email marketing preferences;
  • financial information (including credit card or account information);
  • information such as your nationality and country of residence that allows us to determine your eligibility under export control regulations to receive information about certain technologies;
  • information used to customize and facilitate your use of our websites, including login and technical information;
  • inquiries about and orders for our products and services;
  • information that assists us in identifying the products and services that best suit your requirements;
  • information that assists us in improving our products and services;
  • event registration information;
  • feedback from you about our websites and our products and services generally; and
  • any information as collected pursuant to the description under "information collected automatically" below.

We may collect the following information, including personal information while you are using SHO Products and Services as defined in Terms of Services, including SHO Site, SHO Web Services, SHO Mobile Apps, and SHO Subscribed Services:

  • Setup information and account information you provide, such as your date of birth, gender, email address and Wi-Fi network information;
  • Data from the sensors built into the device, such as motion sensors, temperature sensors, light sensors, humidity sensors;
  • Video and audio signals and data;
  • Technical, usage and performance information from the device;
  • Shared content.

You are not required to provide any of this information, but if you do not, we may not be able to provide you the requested service or complete your transaction.

Information collected automatically

We collect information about your visit to our sites, including what pages you view, the number of bytes transferred, the links you click, the materials you access, and other actions taken within SHO's sites. On sites that you enter with a user ID, we may connect this information with your identity to determine your potential interests in our products and services. We also collect certain standard information that your browser sends to every website you visit, such as your Internet Protocol (IP) address, your browser type and capabilities and language, your operating system, the date and time you access the site, and the website from which you linked to our site to analyze trends in the aggregate and administer the site. . We do not link this information to your identity.

Cookies and Tracking Technologies

SHO Technology and its partners use cookies or similar technologies to analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

To manage Flash cookies, please click here:  http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

We may partner with a third party to display advertising on our website or to manage our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here. Please note you will continue to receive generic ads.

How does SHO use your personal information?

SHO uses the information we collect about you in a number of ways, such as:

  • Providing you with products and services as well as any support or information you have requested;
  • Better understanding how products and services are being used so we can improve them;
  • Diagnosing problems in our products and services;
  • Sending you business messages such as those related to payments or expiration of your subscription;
  • Sending you information about SHO and its controlled subsidiaries and affiliates, such as new application releases, special offers, and similar information;
  • Reducing fraud, software piracy, and protecting our customers as well as SHO;
  • To administer our services or website (including any searches or requests for information about our products or services);
  • For assessment and analysis of our market, customers, products and services, including asking you for your opinions on our products and Services and carrying out customer surveys;
  • To enable us to monitor, review and improve the products and services which we offer;
  • For internal record keeping.

Mobile Application

When you download and use our Services, we automatically collect information on the type of device you use, operating system version and system and performance information.

We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.

We collect your location based information for the purpose of allowing you to share your location while using the Moments function. We will only share this information with our mapping provider for the sole purpose of providing you this service. You may opt-out of location based services at any time by editing the setting at the device level or by emailing us at [email protected]

We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

Disclosure of your personal information

Except as described below, personal information you provide to SHO will not be shared outside of SHO and its controlled subsidiaries and affiliates without your permission.

Disclosure to service providers. SHO contracts with other companies to provide services on our behalf, such as hosting websites, sending out information, processing transactions, and analyzing our websites. We provide these companies with only those elements of your personal information they need to deliver those services. These companies and their employees are prohibited from using that personal information for any other purpose.

Disclosure to distributors. In responding to a request made by you, we may share your personal information with companies that distribute our products. In those cases, we provide these companies with only those elements of your personal information they need to respond to your request, and these companies and their employees are prohibited from using that personal information for any other purpose. In some cases, we may seek your permission to share your information with distributors for marketing purposes other than responding to a request from you. However, we will not share your information for such marketing purposes unless we have obtained your express consent to do so.

Disclosure in connection with transactions. In connection with certain transactions, we may disclose some or all of your personal information to financial institutions, government entities, and shipping companies or postal services involved in fulfillment.

Disclosures in connection with acquisitions or divestitures. Circumstances may arise where for strategic or other business reasons SHO decides to sell, buy, merge or otherwise reorganize businesses in some countries. Such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or receiving it from sellers. It is SHO's practice to seek appropriate protection for information in these types of transactions.

Disclosure for other reasons. We may disclose personal information if required in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, to do so by law or in the good-faith belief that such action is necessary to comply with legal requirements or with legal process served on us, to protect and defend our rights or property, or in urgent circumstances to protect the personal safety of any individual.

We may also disclose your personal information to any other third party with your prior consent.

Minors

SHO does not knowingly collect or store any personal information about children under the age of 13.

Consent to international transfers of personal information

The personal information we collect on our websites may be sent to the United States or to any other country in which SHO or its affiliates, subsidiaries or agents maintain facilities. We may also store and process the information there. Although the laws that protect personal information in those countries may differ from the laws where you live, we will take reasonable steps to ensure that your privacy is protected. By using our websites and giving your information to us, you consent to the transfer of the data outside of your country.

Security

We are committed to ensure that your Personal Data is kept and stored securely and we maintain reasonable physical, technical and organizational measures and procedures to safeguard and secure the information we collect through our Services and our website.

This has been done with a view to preventing unauthorized or unlawful processing of your Personal Data and accidental, unauthorized or unlawful access, use, processing, copying, alteration, transfer, loss or destruction of, or damage to your Personal Data. Whilst we have done all of this, and comply with the standards required by applicable laws, we cannot guarantee that your Personal Data is secure when submitted or otherwise communicated through insecure means. We protect the security of your Personal Data by:

  • using encryption where appropriate;
  • using password protection where appropriate;and
  • limiting access to your Personal Data (for example, only our staff or employees who need access to it for the purposes described in this Privacy Policy will have access to it).

However, these measures do not release you from taking appropriate steps to keep your Personal Data safe and secure, in particular by avoiding obvious user ID's or passwords, by changing your password regularly and by ensuring that you do not disclose your password(s) or grant any other person access to your user account and your Personal Data.

We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. If you have any questions about the security of your personal information, you can contact us at [email protected].

Reviewing your personal information

Upon request SHO Technology will provide you with information about whether we hold any of your personal information.

In some cases, you can review, correct, request deletion of personal information provided through our websites by going to the page on which you provided the information. In all cases, you can make a request to review and correct your personal information collected via our websites or asks SHO to stop using it by completing our Contact Us form. We may take steps to verify your identity before providing you access to your personal information. You can help us to maintain the accuracy of your information by notifying us of any change to your mailing address, phone number, or email address. We will respond to your request within a reasonable timeframe.

Note that we need to retain certain records for legal or internal business reasons and that some of your information may remain on backup systems, in compliance with applicable law. We will retain your personal information for as long as necessary to provide you with the websites and applications you are eligible to use with your SHO ID, or as needed to comply with our legal obligations, may need to retain your personal information in order to continue providing a service or enforce our agreements.

Email Preferences

You may sign-up to receive email or newsletter or other communications from us.  If you would like to discontinue receiving this information, you may update your email preferences by using the "Unsubscribe" link found in emails we send to you or at your member profile on our website or by contacting us at [email protected].

Data processing, storage, and transfers where the GDPR applies

This section only applies to the personal data of those to whom the General Data Protection Regulation applies.

Who is the controller of your personal data?

A data controller is the entity that directs the processing of your data and is chiefly responsible for the data. Generally, SHO will be the controller of data collected pursuant to this Notice.

Is your data transferred to other countries?

As part of delivering service to you, SHO and its affiliates may transfer your data between countries. The privacy protections and legal requirements in some of these countries may not be the same as those in your country. These transfers occur between SHO entities and our service providers.

Your Permission

By using our Site and/or Services, you are explicitly consenting to this transfer of your information, including personal data. We may also use appropriate safeguards, namely contractual protections for the transfer of Personal Information to third parties, such as the European Commission’s Standard Contractual Clauses, where appropriate.

Please note that any information you publish publicly on our Sites or services may be accessed globally.

Where does SHO store the data it collects?

SHO uses servers located in the United States of America. By using SHO’s Services, you agree to having your data stored transferred to, processed and stored in the United States of America.

Why does SHO collect and process data?

SHO relies on the following legal bases to collect, process, transfer, and store your personal data:

  • To allow us to enter into or fulfill the terms of a contract with you. We may need to collect and process your personal information in order to enter into or complete a contract that you are a party to, for example, we may need your name and address to deliver products to you after you order them.
  • To allow us or our partners to fulfill our legitimate business interests, such as:
    1. Preventing fraud;
    2. Maintaining the security of our products and services;
    3. Conducting daily business operations;
    4. Conducting direct marketing;
    5. Providing, maintaining, and improving our products and services;
    6. Managing user account;
    7. Managing our products and services;
    8. Performing research that improves our products or services for the users or public;
    9. Fulfilling obligations to our partners.
  • To comply with legal obligations. SHO may be required to process and/or disclose your personal data when legally required to do so as in when filing taxes or answering law enforcement subpoenas. SHO may also disclose your information if required in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, to comply with legal obligations, or when we believe in good faith that the law requires it. We may also disclose your personal information to verify or enforce our Terms & Conditions or other policies, or to otherwise protect the rights, property, safety, or security of third parties, visitors to our Sites or the public. SHO has strict internal policies regarding when and how your information can be disclosed to legal authorities.
  • To process your information after obtaining specific consent from you to do so. For example, to contact you with special offers after you grant SHO consent to contact you with marketing material. Whenever consent is used to process your data you be provided with details on how that information will be used before you grant consent. You have the right to withdraw consent for this type of processing at any time. Withdrawal of consent will not affect the lawfulness of processing performed before consent is withdrawn. Information on how to withdraw consent will be provided before your information is processed based on your consent.

What rights do I have?

The following rights are available under the General Data Protection Regulation. Please read the relevant laws and guidance from the applicable regulatory authorities for further information on these rights.

  • The right to be informed;
  • The right of access;
  • The right of rectification;
  • The right to erasure;
  • The right to restrict processing;
  • The right to data portability;
  • The right to object;
  • Rights in relation to automated decision making and profiling.

In addition to the above-mentioned rights, if we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

You also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.

How can I exercise my rights?

If you would like to exercise any of yours rights under an applicable law, please contact us at SHO Technologies Inc., 200 West Madison Suite 2100 PMB# 228 Chicago, IL 60606, Attn: Privacy Office, or submit an email to  [email protected]. In order to protect your identity and the security of your personal data, SHO reserves the right to take reasonable steps to verify your identity before acting on any requests. SHO also reserves the right to charge a reasonable amount for requests.

Your California Privacy Rights

Under Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for those third parties' direct marketing purposes, and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at  [email protected]  with "Request for California Privacy Information" as the subject line. Please be sure to provide in the body of your email request sufficient information to properly identify you and/or the members of your family.

Changes to this privacy policy

SHO may occasionally update this privacy policy. When we do, we will revise the "last updated" date at the top and bottom of the privacy policy. If we make any material changes we will notify you by email sent to the email address specified in your account or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Enforcement of this privacy policy

If you do not wish to receive email or other mail from us, contact us at [email protected]. Please note that if you do not want to receive legal notices from us, such as this Privacy Policy, those legal notices will still govern your use of the Service, and you are responsible for reviewing such legal notices for changes.

If you have questions regarding this statement or our handling of your personal information, please contact us. We will promptly address your concern and strive to reach a satisfactory resolution.


SHO Technologies Inc.
200 West Madison Suite 2100 PMB# 228 Chicago, IL 60606
[email protected]