1. DEFINITIONS AND INTERPRETATION

1.1 Defined Terms

In this Privacy Policy:

End User means a consumer that has requested a calendar subscription from an Advertiser through the CalReply service.

Advertiser means the company using the CalReply services that has entered into an agreement with ShopReply Pty Ltd.

Personal Information has the meaning given to it in the Privacy Act 1988 (Cth).

Privacy Policy means this policy.

Usage Data means analytics, statistics or other data related to the End User, or the use of the ShopReply services.

1.1 Interpretation

In this Privacy Policy, except where the context otherwise requires:

(a) the singular includes the plural and vice versa, and a gender includes other genders;

(b) another grammatical form of a defined word or expression has a corresponding meaning;

(c) a reference to a statute, ordinance, code or other law includes regulations and other instruments under it and consolidations, amendments, reenactments or replacements of any of them;

(d) the meaning of general words is not limited by specific examples introduced by including, for example or similar expressions; and

(e) a rule of construction does not apply to the disadvantage of a party because the party was responsible for the preparation of this Privacy Policy or any part of it.

2. INFORMATION WE COLLECT

When a user requests a calendar subscription we collect the following information:

(a) Twitter handle and Tweet object data from the inbound Tweet

(b) When you use our service: we record your subscriber activity, device, and sometimes information about your computer or access device.

(c) Additional information from or about you may also be collected in other ways, including responses to customer surveys or your communications with our customer service team.

(d) Advertisers may opt to collect and store your email address. Email addresses of Google Calendar users are stored by default however the Advertiser is not permitted to market to these addresses unless express consent is received by the End User.

3. WE USE TECHNOLOGY TO HELP US COLLECT INFORMATION

3.1 Cookies

(a) It is important for us to track how our website is used, and we (or our service providers) may place “cookies” on your computer or device. Cookies are small data files that identify you when you use our services.

(b) You have the option to decline our cookies by using your browsers settings tools, but this may interfere with your use of our website and services.

3.2 Log File Information

(a) Log file information is automatically reported by your browser each time you access a web page. When you register with or view our site, our servers automatically record certain information that your web browser sends whenever you visit any website.

(b) These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.

4. USE OF PERSONAL INFORMATION

4.1 Protecting Personal information

(a) Any information that can be used to identify a person is “Personal Information”. This does not include information that has been aggregated or made anonymous.

(b) All information is securely stored on our servers. Our safeguards and procedures have been implemented in accordance with United States state and federal law and regulations to maintain the physical and electronic security of our software, services and your Personal Information. Our measures include firewalls, system-wide data encryption, physical and electronic access controls, and strict rules regarding the access and use of data on our system.

4.2 Using Personal Information

(a) We use your Personal Information to provide you the features and functionality of the service, and may share it with our trusted third parties, to ensure that you have a safe, high-performance experience when using the service. When you use the Service, including adding a calendar subscription, contacting customer service or requesting technical support, in addition to many other interactions with ShopReply, we will apply the information that we have collected. Knowing this information allows us to verify your identity, communicate with you and enforce our agreements with you, as well as secure the best possible experience for all ShopReply members by ensuring compliance with United States state and federal laws and our own policies. We may also use this information to measure how our members use the Service, and improve and enhance our offerings to you.

(b) ShopReply may use certain information about you without identifying you as an individual to third parties. We do this for purposes such as analyzing how the Service is used, diagnosing service or technical problems, maintaining security, and personalizing content.

(c) We use cookies and log file information to:

  1. remember information so that you will not have to re-enter it during your visit or the next time you visit the site;
  2. provide custom, personalized content and information;
  3. monitor the effectiveness of our Service;
  4. monitor aggregate metrics such as total number of visitors and traffic;
  5. diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses; and
  6. help you efficiently access your information after you sign in.

4.3 Sharing Personal information

ShopReply will not rent or sell your Personal Information to others. You consent to ShopReply sharing your Personal Information with third parties for the purpose of providing services to you (such as those described below). If we do this, such third parties’ use of your Personal Information will be bound by terms at least as restrictive as this Privacy Policy. You consent to ShopReply storing Personal Information in locations outside the direct control of ShopReply (for instance, on servers or databases co-located with hosting providers). Facilitating this service requires that we share your Personal Information and Usage Data with third parties; you consent to us sharing your Personal Information and Usage Data with third parties, including but not limited to:

(a) Service providers who provide us a range of essential operational services including managed technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.

(b) Advertisers who utilise the ShopReply Platform to enable subscriptions between you and the Advertiser.

(c) Law enforcement authorities or government representatives who may require us to share information in order to comply with court order and other legal mandates, or when we believe that disclosure is necessary to report suspicious activities, prevent physical harm, financial loss, or violations of our agreements and policies.

(d) Other third parties, subject to your prior consent or direction.

As we develop our business, we may buy or sell assets or business offerings. Customer, End User, transaction, email, and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer such information in the course of corporate divestitures, mergers, or dissolution.

From time to time, we may run contests, special offers, or other events or activities on the Service together with third party partners. If you provide information to such third parties, you give them permission to use it for the purpose of that event and any other use that you approve. We cannot control third parties’ use of your information. If you do not want your information to be collected by or shared with a third party, you can choose not to participate in these events.

4.4 Off shore data transfers

From time to time, ShopReply may transfer Usage Data or Personal Information to servers located outside of the United States. By using the ShopReply services and agreeing to this Privacy Policy, you explicitly consent to allowing ShopReply to transfer your Personal information and Usage Data off-shore, provided that it remains subject to this Privacy Policy.

4.5 Disclosures required by law or for personal safety

Except as otherwise described in this Privacy Policy, ShopReply will not disclose Personal Information to any third party unless required to do so by law or subpoena or if we believe that such action is necessary to:

  1. conform to the law, comply with legal process served on us or our affiliates, or investigate, prevent, or take action regarding suspected or actual illegal activities;
  2. to enforce our End User agreement, take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of our site; and
  3. to exercise or protect the rights, property, or personal safety of ShopReply, our End Users or others.

 5. SECURITY

5.1 Compromise of Personal Information

In the event that Personal Information is compromised as a result of a breach of security, ShopReply will promptly notify those persons whose Personal Information has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, by email, or as otherwise required by applicable law.

5.2 Your choices about your information

You may, of course, decline to submit Personal Information through the service, in which case ShopReply may not be able to provide certain services to you. You may update or correct your account information at any time by logging in to your account. You can review and correct the information about you that ShopReply keeps on file by contacting us as described below.

5.3 Children’s privacy

(a) Protecting the privacy of young children is especially important. For that reason, ShopReply does not knowingly collect or solicit Personal Information from anyone under the age of 18 or knowingly allow such persons to register with our service.

(b) If you are under 18, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 18 is allowed to provide any Personal Information to or on ShopReply.

(c) In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us as described below.

5.4 Links to other websites

ShopReply is not responsible for the practices employed by websites linked to or from our website, nor the information or content contained therein. Please remember that when you use a link to go from our website to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our website, is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding.

5.5 Notification procedures

It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email notice, written or hard copy notice, or through conspicuous posting of such notice on our website, as determined by ShopReply in its sole discretion. We reserve the right to determine the form and means of providing notifications to you.

6. CHANGES

6.1 Changes to our Privacy Policy

If we change our Privacy Policy or procedures, we will post those changes on our website to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page.

6.2 Contact

Please contact our Privacy Department with any questions or concerns regarding our policy.

ShopReply Pty Ltd

33 Irving Place
Floor 5
New York, NY 10003
United States

Effective Date: 30 May 2013

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