Effective Date: May 25, 2018
Sure Shot Labs, LLC (“Sureshot”, “we”, “us” or “our”) operates the SureShot Platform (the “App”) and the associated services, as well as the sureshot.io website (collectively, the “Services”). This privacy policy (“Privacy Policy”) describes the types of information that we may collect or you may provide when you register with, access or use the Services. This Privacy Policy also describes our practices for collecting, using, disclosing, and maintaining such information. “Personal information” is data that can be used to uniquely identify or contact a single person.
This Privacy Policy applies only to information we collect or you provide via the Services. This Privacy Policy does not apply to information we collect offline or that you provide to third-party websites you may access through the Services (see “Third-Party Links” section below). These third parties may have their own privacy policies, which govern how information is collected and used, and we encourage you to read the policies before providing information on or through them.
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. Along with this Privacy Policy, please read our Terms of Use, which are hereby incorporated and made part of this Privacy Policy. If you do not agree with our policies and practices, do not register with, access or use the SERVICES. By registering with, accessing or using the Services, you agree to the terms and conditions of this Privacy Policy.
Our Details. Sureshot provides cloud-based customer engagement solutions to help solve marketing operations challenges that impact data management, campaign execution, and the customer lifecycle.
For the purpose of the General Data Protection Regulation (the “GDPR” or “data protection law”) in respect to personal information of users of the Services (our “Clients”), we are the data controller. This is because we dictate the purpose for which your personal information is used and how we use your personal information. We fairly process your information under relevant law. If you have any questions about how your data is kept or if you wish to exercise one or more of your rights in regard to the data we keep on you, you may call 469.919.5779 (ext. 403), or contact us by email at privacy@sureshot.io with the subject line “My Privacy Rights”, or regular mail at 1431 West Morehead St. Charlotte, NC 28208.
For the purposes of data protection law, in respect of personal information of persons who are contacts of our Clients, we shall process personal information as a data processor on behalf of our Clients, who use our Services to assist with marketing challenges. If you are a contact of one of our Clients, our Client’s privacy policy, rather than this Privacy Policy, will apply to our processing of your personal information.
Changes to This Privacy Policy. We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business activities and legal requirements, and the manner in which we process personal information. We encourage you to review this Privacy Policy periodically. We will place updates on the website, inform you of the updates and where appropriate we will give reasonable notice of any changes. Any changes to the Privacy Policy will become effective upon posting of the revised policy. By continuing to use the Services following any such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Privacy Policy, in whole or part, you can choose to discontinue use the Services. This Privacy Policy was last updated on May 25, 2018.
Information We Collect and How We Collect It. We may collect information from and about our users when you provide it to us (e.g., when you register with our Services, subscribe to our newsletter, respond to a survey, or complete a form) or automatically while you use the Services.
Information You Provide to Us; Account Information. When you register with or use the Services, we may ask you to provide certain personal information, including name, email address and phone number. For example, when you use the “Create a user” form on the Services, we collect information you submit, including first name, last name, email address, and password. We may also use features on the Services, such as the “Contact Us” icon, to provide you with the opportunity to contact us to ask questions, request information, or provide comments or suggestions. We may also ask you for information if you enter a contest or promotion sponsored by us or if you respond to one of our surveys. You may be offered the opportunity to have one of our representatives contact you to provide you additional information about our Services (e.g., if you select “Contact Us” button on the Services or if we request feedback about the Services).
Automatic Collection. When you register with or use the Services, the Services may use technologies to automatically collect usage information (e.g., your use of features of the Services) and device information (e.g., device type, mobile network information, unique device identifier, operating system, browser type, application version). This information is sometimes called “traffic data” and helps us improve and customize the Services. This information is generally non-identifying, but if we associate it with you as an identifiable person, we will treat it as personal information.
Technologies Used to Automatically Collect Information. Technologies we use on the Services to collect traffic data, directly or through our service providers, may include cookies (data files placed on the device you use to access the Services), analytics software (e.g., Google Analytics) and pixel tags (transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or email has been viewed). A pixel tag may tell your browser to get content from another server. We, or our service providers, may place cookies or similar files on your device used to access the Services for security purposes, to facilitate navigation and to personalize your experience while using the Services. It may be possible to refuse to accept cookies by activating the appropriate setting on your device or in the browser used to access the Services. However, if you refuse to accept cookies you may be unable to access all or parts of our Services and some of our features and Services may not operate as intended.
How We Use Information Collected From You; Legal Bases for Processing Your Information. We use information we collect about you or you provide to us, including any personal information, to provide you with the Services, and to provide other information, products, offers or services you request from us, fulfill any other purpose for which you provide such information, to communicate with you about our Services, provide offers and promotions to you, give you notice about our offers and promotions, notify you when Services updates are available, and of any changes to any of our Services we offer. The usage information helps us improve our Services and to deliver a better and more personalized experience by enabling us to estimate our audience size and usage patterns, store information about your preferences and recognize you when you use the Services.
| Purpose | Legal Basis |
| To provide our website to you. | This is in our legitimate interest (i.e., the provision of the website to you). |
| To provide you with the Services we offer (including any promotions). | This is in our legitimate interest (i.e., the provision of the Services to you), and depending on the circumstances, to perform a contract between you and us. |
| To communicate with you and other individuals and to carry out your requests and respond to your communications. | This is in our legitimate interest (i.e., the provision and support of the website and Services) |
| To carry out our obligations arising from any contracts entered into between you and us. | This is to perform a contract between you and us. |
| To notify you about changes to the website. | This is in our legitimate interest (i.e., the provision of the website and Services). |
| To audit and monitor the use of the website and Services and to improve the quality of the website and Services. | This is in our legitimate interest (i.e., the provision and support of the website and Services, improvement and development of our business operations as well as to improve and ensure the security of the website and those Services).
We may request your consent in circumstances where a legal justification over and above legitimate interests is required by applicable law (e.g., in relation to our use of certain cookies). |
| To manage complaints, feedback and questions. | This is in our legitimate interests (i.e., the provision and support of the website and Services and improvements and development of our business operations). |
| To provide you with information about the Services we offer in accordance with your preferences as indicated, including any marketing consent preferences. | We can do this based on your consent. |
| To comply with any legal or regulatory obligations (including in connection with a court order and establishing, exercising or defending legal claims). | This is in our legitimate interests (i.e., protection of our business, employees and customers) and for compliance with legal obligations to which we are subject. |
| To enforce or apply the agreements concerning you (including agreements between you and us). | This is in our legitimate interest (i.e., protection of our business, employees and customers). |
Disclosure of Your Information. We may use or disclose your information, including personal information, to our third-parties to protect the security and integrity of the Services, to correct technical problems and malfunctions on the Services, to technically process your information, to fulfill our offers, promotions and coupons, to provide the Services to you, and/or to take precautions against liability. If you are located in the EU or EEA, review the “Transfers Outside of the European Union/European Economic Area” section below for more information about how your information may be transferred outside of the EU or EEA.
We may also provide your information to our service providers who provide services on our behalf.
We reserve the right to transfer any information we have about you in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of our business.
We reserve the right to disclose any personal information as needed if that information is requested by law enforcement agencies or if we are required to do so by law, treaty, regulation, subpoena, court order, or by a government entity.
We also may disclose your personal information to third parties if we have reason to believe that disclosing such information is necessary to conduct investigations of possible breaches of law, to cooperate in any legal investigation, or to identify, contact, or bring legal action against someone who may be violating any agreement with us.
Do-Not-Track Requests; Third-Party Tracking. Unless your browser or device settings are configured to make your Services activities and publicly available information about your Services activities (such as traffic data described above) invisible to usage analytics tools, we do not presently have the capability to omit you from usage analytics to the extent your browser only sends a “do not track” message and does not otherwise screen you from tracking without any action on our part. To learn more about browser tracking signals and “Do Not Track”, please visit http://allaboutdnt.org. Third parties, other than our service providers, do not have authorization from us to track which websites, apps, or other online services you visit prior to and after using the Services. Please note, however, that we cannot control third-party tracking and there may be some third-party tracking that occurs without our consent or knowledge.
Changes in Personal Information; Opt-Out; Your Choices. If you need to correct, update, or delete your personal information, please contact us at any time by sending an email to privacy@sureshot.io. Please note that we may not be able to correct or update your personal information previously provided to us by third parties. You can also choose to delete your account.
- Opt-Out: If you receive any promotional email communication from us, you will be given the option to “unsubscribe” from receiving further email communications from us at any time. Your option not to receive promotional and marketing material from us will not preclude us from corresponding with you, by email or otherwise, regarding existing or past business relationships with us, and will not preclude us from accessing and viewing your personal information in the course of maintaining and improving our Services.
- Cookies: You can set your browser to refuse all or some cookies or alert you when cookies are being sent. If you disable or refuse cookies or block the use of other technologies, some parts of the Services may then be inaccessible or not function properly.
Security; Retention Period. We take reasonable security precautions to protect the personal information that you choose to provide. Although guaranteed security does not exist on the internet or offline, we make commercially reasonable efforts to handle such information consistent with this Privacy Policy and applicable laws. Due to the design of the internet and other factors outside our control, we cannot guarantee communications between you and our servers will be free from unauthorized access by third parties. For more information about our security practices, please review our Security Policy. We will retain your personal information for as long as is necessary for purposes for which it was collected, including to provide you with the Services and to conduct our legitimate business interests or where otherwise required by law. The precise period will depend on the reason why it was collected. For example: for marketing purposes your personal information will be retained until you withdraw your consent and in relation to questions or comments until your question has been dealt with and a reasonable period thereafter or as long as the law requires. Once the retention period for each situation has expired we will take all reasonable steps to destroy or erase from our systems all personal data that we no longer require in accordance with all our applicable record retention schedules and policies.
Third-Party Links. The Services may contain links to third-party websites that are not controlled by us. These links are made available to you as a convenience, and you agree to use these links at your own risk. Please be aware that we are not responsible for the privacy policies and practices or content of such third-party sites. This Privacy Policy only applies to information we collect from you while you are using the Services. If you navigate to a third-party website from the Services, we encourage you to review and become familiar with such third-party website’s privacy policy and statements.
Children. The Services are intended for adults and not intended for children under 18 years of age (or the age of majority in your jurisdiction of residence, if higher), and we do not knowingly collect any personal information from children. If we learn we have collected or received personal information from any such individual, we will take steps to delete the information as soon as possible. If you are under the age of 18 (or the age of majority in your jurisdiction of residence, if higher), please do not provide any personal information to us.
Notice to Residents of Countries Outside the United States. We are headquartered in the United States. Personal information may be accessed or used by us or transferred to us in the United States or to our affiliates, business partners, or service providers elsewhere in the world. If you are located outside the United States, be advised that any information you provide to us will be transferred to and stored in the United States and that, by submitting information to us, you explicitly authorize its transfer and storage within the United States. We will treat the personal information subject to this Privacy Policy according to this Privacy Policy regardless of where it is processed or stored.
Transfers Outside of the European Union/European Economic Area
Due to the global nature of our business, and in order to provide our Service, we may need to transfer your personal information to locations outside the jurisdiction in which you provide it or where you are viewing this website for the purposes set out in this Privacy Policy. This may include a transfer of your information from a location within the European Economic Area (the “EEA”), which includes the member states of the European Union (the “EU”) to outside the EEA, or from outside the EEA to a location within the EEA.
Please review “Disclosure of Information” section above for more detail on how the information may be shared with our third party vendors.
The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. Where our third party vendors process personal data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures, usually standard contractual clauses. For more information about the measures in place, please contact us (see “Contact Us” section).
Your Rights
| Summary of your rights | |
| Right of access to your personal information | You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions. |
| Right to rectify your personal information | You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete. |
| Right to erasure of your personal information: | You have the right to ask that your personal information be deleted in certain circumstances. For example (i) where your personal information is no longer necessary in relation to the purposes for which they were collected or otherwise used; (ii) if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal information; (iii) if you object to the use of your personal information (as set out below); (iv) if we have used your personal information unlawfully; or (v) if your personal information needs to be erased to comply with a legal obligation. |
| Right to restrict the use of your personal information | You have the right to suspend our use of your personal information in certain circumstances. For example (i) where you think your personal information is inaccurate and only for such period to enable us to verify the accuracy of your personal information; (ii) the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead; (iii) we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defence of legal claims; or (iv) you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection. |
| Right to object to the use of your personal information | You have the right to object to the use of your personal information in certain circumstances. For example (i) where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party); and (ii) if you object to the use of your personal information for direct marketing purposes. |
| Right to data portability | You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible. The right only applies where the use of your personal information is based on your consent or for the performance of a contract, and when the use of your personal information is carried out by automated (i.e. electronic) means. |
| Right to withdraw consent | You have the right to withdraw your consent at any time where we rely on consent to use your personal information. |
| Right to complain to the relevant data protection authority | You have the right to complain to the relevant data protection authority where you think we have not used your personal information in accordance with data protection law. You may lodge a complaint with the authority in the member state of your habitual residence or of an alleged infringement of data protection law. |
Your California Privacy Rights. Pursuant to Section 1798.83 of the California Civil Code, California residents have the right to request from a business with whom the California resident has an established business relationship: (1) What types of personal information, if any, of the California resident the business shares with third parties for direct marketing purposes of those third parties; and (2) the identities of the third parties with whom the business has shared such information in the immediately preceding calendar year.
We do not currently share any personal information with third parties for their direct marketing purposes. If you have any questions, comments or requests related to this section of the Privacy Policy, please contact us by email at privacy@sureshot.io. A number of states are currently considering enacting laws similar to the California law mentioned above. If you are a resident of a state that enacts such a law, please use the contact information above to contact us with any questions, comments or requests.
Contact Us. To ask questions or comment about this Privacy Policy and our privacy policies and practices, you may contact us at privacy@sureshot.io or visit the website at sureshot.io.