Additional EEA, Switzerland and UK Privacy Disclosures
Unless otherwise expressly stated, capitalized terms in these Disclosures have the same meaning as defined in the Privacy Policy.
Scope of Disclosures
These Additional European Economic Area (“EEA”), Switzerland and United Kingdom (“UK”) Privacy Disclosures (“European Privacy Disclosures”) supplement the information contained in our Privacy Policy. However, these European Privacy Disclosures apply only to our processing of your Personal Data where you are based in the EEA, Switzerland or the UK.
Personal Data Disclosures
When we use the term “Personal Data” in these European Privacy Disclosures, we mean any information relating to an identified or identifiable natural person.
Legal Bases for Processing
We use the Personal Data we collect about you in the following ways and rely on the following legal grounds to process Personal Data about you, whether it is obtained from you or a third party:
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| Contact information, such as name, phone number and email address. |
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| Data collected through the use of our Services, including information about how you use our Services, your actions on our Services, including feedback through the Services. |
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| Your preferences, such as preferences set for notifications, marketing communications. |
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| Payment information. When you purchase our products and Services, we will collect confirmation of your payment from the payment processor. |
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| Location information, we do not collect information about your precise location (other than information you choose to provide us); however, your WiFi, wireless network triangulation, or your IP address may help us determine an approximate location. |
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| Information contained in communications between you and Shogun, including any information you provide when you contact us or interact with us directly, such as by participating in a contest or promotion, or submitting feedback or other information to us. |
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| Information about how you access and use our Services, including usage history, and your clicking and browsing patterns. |
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| Internet and network information, including device information, logs and analytics data. |
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| All Personal Data set out above and in our Privacy Policy. |
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We use the Personal Data we automatically collect about you in the following ways and rely on the following legal grounds to process Personal Data about you, whether it is obtained from you or a third party:
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You are not required to provide Personal Data to us, but we do rely on your Personal Data to provide certain of our services and products. For example, we need your Personal Data to facilitate and deliver an order that you request. If you choose not to provide us with your Personal Data, we may not be able to provide you with a service or product you request.
Data Retention
We retain Personal Data about you for as long as is necessary for the purposes set out in these European Privacy Disclosures, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights.
The criteria used to determine the period for which Personal Data about you will be retained varies depending on the legal basis under which we process the Personal Data:
| Legitimate Interests | Where we are processing Personal Data based on our legitimate interests, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of data subjects. |
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| Consent | Where we are processing Personal Data based on your consent, we generally will retain the information for the period of time necessary to fulfill the underlying agreement with you, subject to your right, under certain circumstances, to have certain of your data erased (please see the Your Privacy Rights section below). |
| Contract | Where we are processing Personal Data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship. |
| Legal Obligation | Where we are processing Personal Data based on a legal obligation, we generally will retain the information for the period of time necessary to fulfil the legal obligation. |
| Legal Claim | We may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved. |
In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the Personal Data, as well as the potential risk of harm from unauthorized use or disclosure of your Personal Data.
International Data Transfers
We may transfer Personal Data about you among us and to our subsidiaries or affiliates, as well as to the categories of third parties identified in the Our Disclosure of Personal Information section of the Privacy Policy. Personal Data may be transferred to, stored and processed in a country other than the one in which it was collected, including, but not limited to, the United States. The country to which Personal Data is transferred may not provide the same level of protection for Personal Data as the country from which it was transferred.
We may transfer Personal Data about you outside the EEA, Switzerland and the UK, and when we do so, we rely on appropriate or suitable safeguards recognized under the European Union General Data Protection Regulation (the “GDPR”) including adequacy decisions and standard contractual clauses.
Adequacy Decisions
We may transfer Personal Data about you to countries that the European Commission has deemed to adequately safeguard Personal Data.
Standard Contractual Clauses
The European Commission has adopted Standard Contractual Clauses, which provide safeguards for Personal Data transferred outside of the EEA, Switzerland and the UK. We may use these Standard Contractual Clauses when transferring Personal Data from a country in the EEA, Switzerland or the UK to a country outside the EEA, Switzerland or the UK that has not been deemed to adequately safeguard Personal Data. You can request a copy of our Standard Contractual Clauses by contacting us as set forth in the Contact Us section below.
Your Privacy Rights
You have the following rights in relation to your Personal Data (subject to certain limitations at law):
| Access | The right to obtain:
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| Rectification | The right to correct or update any Personal Data about you that is inaccurate or incomplete. |
| Restriction of Processing | The right to require us to limit the purposes for which we process your Personal Data if the continued processing of the Personal Data in this way is not justified, such as where the accuracy of the Personal Data is contested by you. |
| Erasure | The right to request the deletion or erasure of Personal Data about you without undue delay if the continued processing of that Personal Data is not justified. |
| Portability | The right to obtain a copy of Personal Data about you in an easily accessible format and the right to transmit that Personal Data to another controller. |
| Obejection to Processing | You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your Personal Data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason. |
Please note that if the exercise of these rights limits our ability to process Personal Data, we may not be able to provide our products or services to you, or otherwise engage with you going forward.
Right to Withdraw Consent
Where we rely on your consent for processing of your Personal Data, as identified in the Legal Bases for Processing section above, you also have the right to withdraw your consent to such processing. You may withdraw your consent at any time by contacting us using the contact details at the end of these European Privacy Disclosures.
Submitting Requests
To submit a request, please contact us as set forth in the Contact Us section below. We may need to verify your identity before processing your request, which may require us to obtain additional Personal Data from you. In certain circumstances, we may decline a request to exercise the rights described above.
Right to Lodge a Complaint
If you have any complaints regarding our privacy practices, you have the right to lodge a complaint with your national data protection authority (i.e., supervisory authority). If you are based in the EEA, Switzerland or UK, information about how to contact your local data protection authority is available here. However, we encourage you to first reach out to us by using the contact details set out in the Contact Us section below so that you have an opportunity to address your concerns directly and so that we may find a solution together before you do lodge a complaint.
Updates to These Disclosures
We may update these European Privacy Disclosures from time to time. When we make changes to these European Privacy Disclosures, we will change the “Last Updated” date at the beginning of these European Privacy Disclosures. If we make material changes to these European Privacy Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Contact Us
If you have any questions or requests in connection with these European Privacy Disclosures or other privacy-related matters, please call send an email to privacy@getshogun.com.
Alternatively, inquiries may be addressed to:
Shogun Labs, Inc.
Attn: Privacy Department
340 S Lemon Ave #1085
Walnut, CA 91789