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:
| Category of Personal Data |
How We Use the Personal Data |
Legal Basis for Processing |
| Contact information, such as name, phone number and email address. |
We use this information to communicate with you, including sending service-related communications. |
The processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract. |
| We use this information to send you unsolicited marketing communications in accordance with your preferences. |
We will only use your Personal Data in this way to the extent you have given us consent to do so. |
| We use this information to address inquiries and complaints made by you relating to your use of our Services. |
The processing is necessary for our legitimate interests, namely administering our Services and for communicating with you effectively to respond to your queries or complaints. |
| 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. |
We may use information about how you use and connect to our Services to present our Services to you on your device. |
The processing is necessary for our legitimate interests, namely, to tailor our Services to the user. |
| We may use this information to determine products and services that may be of interest to you for marketing purposes. |
The processing is necessary for our legitimate interests, namely, to inform our direct marketing. |
| We may use this information to monitor and improve our Services and business, resolve issues and to inform the development of new products and services. |
The processing is necessary for our legitimate interests, namely, to monitor and resolve issues with our Services and to improve our Services generally. |
| Your preferences, such as preferences set for notifications, marketing communications. |
We use this information to provide our Services to you in accordance with your choices. |
The processing is necessary for our legitimate interests, namely ensuring our Services are displayed in accordance with the user’s preferences. |
| We use this information to ensure that we comply with our legal obligation to send only those marketing communications to which you have consented. |
The processing is necessary for compliance with a legal obligation to which we are subject. |
| Payment information. When you purchase our products and Services, we will collect confirmation of your payment from the payment processor. |
We use this information to record that your payment has been processed and to grant you access to the paid features of our Services. |
The processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract. |
| 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. |
Providing you with content that is more relevant to you based on your location. |
We only process your Personal Data in this way to the extent that you have given us your consent |
| 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. |
We use this information to respond to comments, questions or requests for customer service. |
The processing is necessary for our legitimate interests, namely administering our Services and addressing your queries and concerns. |
| We use this information to address any violations of our Terms of Service, or any other rules, regulations or policies relating to our Services. |
The processing is necessary for the performance of a contract between you and us. |
| Information about how you access and use our Services, including usage history, and your clicking and browsing patterns. |
We use this information to operate, maintain and provide to you the features and functionality of our Services, to improve our products and services, for research and product development. |
The processing is necessary for our legitimate interests, namely, to tailor our Services to you, to improve our Services and to develop new features and functionalities on our Services. |
| Internet and network information, including device information, logs and analytics data. |
We use this information to provide and monitor the effectiveness of our Services; monitor usage of and activities on our Services; diagnose errors and problems with our Services; otherwise plan for and enhance our Services; understand your activities when you use our Services to deliver ads and information about products and services that may be of interest to you. |
The processing is necessary for our legitimate interests, namely, to tailor our Services to you, to improve our Services and to develop new features and functionalities on our Services.
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| All Personal Data set out above and in our Privacy Policy. |
We may use this information to comply with any professional or legal obligation to which we may be subject, such as disclosure of information to comply with a court order or at the request of a regulator. |
The processing is necessary for the compliance with a legal obligation to which we are subject |
| We may use this information to facilitate our internal business operations that are put in place for compliance with our legal obligations. |
The processing is necessary for our legitimate interests, namely the detection and prevention of fraud and the fulfilment of professional obligations. |
| We may use this information to determine products and services that may be of interest to you for marketing purposes. |
The processing is necessary for our legitimate interests, namely, to inform our direct marketing.
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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:
| Category of Personal Data |
How We Use the Personal Data |
Legal Basis for Processing |
| Information about how you access our Services. For example, the site from which you came and the site to which you are going when you leave our websites, how frequently you access the Services, whether you open emails or click the links contained in emails, and whether you access the Services from multiple devices. |
We or the third-party partners we use, may use the data collected through tracking technologies to:- remember information so that you will not have to re-enter it during your visit or the next time you visit our Services;
- provide custom, personalized content and information, including targeted content and advertising;
- identify and contact you across multiple devices;
- provide and monitor the effectiveness of our Services;
- perform analytics and detect usage patterns on our Services;
- diagnose or fix technology problems;
- detect or prevent fraud or other harmful activities, and
- otherwise plan for and enhance our Services.
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The processing is necessary for our legitimate interests, namely: to tailor our Services to the user and to improve our Services generally; to monitor and resolve issues; for marketing purposes; to communicate with users; to contact users; and for the detection and prevention of fraud. For more information on the legal basis for cookies, please see the Cookies and Online Ads section of our Privacy Policy. |
| Information about how you use our Services. For example, the pages you visit, the links you click, the ads you view and click on, your purchase and subscription information, your location when you access or interact with our Services and other similar actions. |
| Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. |
| Analytics information. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for our Services and to understand more about the demographics and behaviors of our users. |
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). |
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| 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. |
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| 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. |
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| 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. |
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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:- confirmation of whether, and where, we are processing your Personal Data;
- information about the categories of Personal Data we are processing, the purposes for which we process your Personal Data and information as to how we determine applicable retention periods;
- information about the categories of recipients with whom we may share your Personal Data; and
- a copy of the Personal Data we hold about you.
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| Rectification | The right to correct or update any Personal Data about you that is inaccurate or incomplete. |
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| 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. |
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| 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. |
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| 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. |
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| 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. |
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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
