Shiller Inc. Privacy Policy
Last Updated: July 2022

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Shiller Inc.and its subsidiaries and affiliates (together, “Shiller” “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:

(i)  When you browse or visit our website, www.shiller.io (“Website”)

(ii)  When you make use of, or interact with, our Website

a. When you with your personal data to apply to be a Shiller
b. When you with your personal data to be kept informed
c. When you provide us with your personal data for marketing reasons
d. When you contact us

(iii) When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

1. What information we collect, why we collect it, and how it is used
2. How we protect and retain your personal data
3. How we share your personal data
4. Additional information regarding transfers of personal data
5. Your privacy rights
6. Use by children
7. Interaction with third party products
8. Log files
9. Analytic tools
10. Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement significant changes to the use of your personal data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

When you browse or visit our Website, App, or Mobile Web Pages

Specific personal data we collect:

• Cookies, analytic tools and log files
• IP, browser, device model

Why is the personal data collected and for what purposes?
We collect this information to optimise the presentation of the platform based on your hardware and software systems, making it more convenient for you to use our services.

Legal basis (GDPR only, if applicable)

• Consent (non essential cookies)
• Legitimate interest (essential cookies)

Third parties with whom we share your personal data

• Google Analytics , Google Tag Manager and Google Search Console – analytics

When you make use of, or interact with, our Website to apply to be a Shiller, register to be kept informed or submit a press/media enquiry

Specific personal data we collect:

• First name
• Last name
• Nickname
• Company Name
• Email address
• Social media accounts
• Any other information which you choose to provide

Why is the personal data collected and for what purposes?

We collect this information to process requests to become Shiller content creators more accurately.

We collect this information to maintain a database to keep you informed.

We collect this information to respond to media & press requests for information about Shiller.

Legal basis (GDPR only, if applicable)

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (e.g. Shiller agreement)

Legitimate interest (e.g., to communicate with you and process your application)

Consent (marketing)

Third parties with whom we share your personal data

• Typeform – permissions to contact, name, email and social media handles
• Video Commerce Group (“OOOOO”) – information processing

Retention period

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

Consequences of not providing the personal data

• Cannot process your application to be a Creator on OOOOO
• Cannot communicate with you
• Cannot send you marketing communications

When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

Specific personal data we collect:

• Full name
• Email address
• Social media channel & handles
• Any other data you decide to provide/supply

Why is the personal data collected and for what purposes?

• To respond to your requests in our social media channels
• To send you marketing communications

Legal basis (GDPR only, if applicable)

• Legitimate interest (e.g. respond to your requests in our social media channels)
• Consent (marketing)

Third parties with whom we share your personal data
Video Commerce Group (“OOOOO”) – Shiller platform management

Retention period
Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

Consequences of not providing the personal data

• Unable to respond to your requests in our social media channels
• Cannot send you marketing communications 

2. HOW WE PROTECT AND RETAIN YOUR INFORMATION

2.1 – Security. We have implemented appropriate technical, organisational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorised penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

2.2 – Retention of your personal data. In addition to the retention periods mentioned above, in some circumstances we may store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings. We have an internal data retention policy to ensure that we do not retain your personal data perpetually.

3. HOW WE SHARE YOUR PERSONAL DATA

 In addition to the recipients described above, we may share your personal data as follows:

3.1 – With our business partners with whom we jointly offer products or services, to help facilitate interactions between Users and Merchants.

3.2 – We may also share Personal Data with our affiliated companies.

3.3 – To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;

3.4 – If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events;

3.5 – In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events; and/or

3.6 – Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

4.1 – External transfers: Where we transfer your personal data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your personal data in line with GDPR requirements.

5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

5.1 – Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;

You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;

You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;

You have the right to object, to or to request restriction, of the processing;

You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;

You have the right to object to profiling;

You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please  note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;

You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;

You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

5.2 – Exercising yor privacy rights: You can exercise your rights by contacting us at [email protected]. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

6. USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [email protected]

7. INTERACTION WITH THIRD PARTY PRODUCTS

If we enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

8. LOG FILES

We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

9. ANALYTIC TOOLS

The Website uses tools called GA4 , GTM and Search Console to collect information about use of the Website. These tools collect information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from these tools to maintain and improve the Website and our products. We do not combine the information collected through the use of these tools with personal information we collect. 

We reserve the right to remove or add new analytic tools.

10. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected]

Data controller: Shiller Inc.