Privacy Policy of Shufflewire

Owner and Data Controller

Shufflewire Limited, 24 King Coel Road, Colchester, CO3 9AQ, United Kingdom

Owner contact email: hello@shufflewire.com

Types of Data collected

Among the types of Personal Data that Shufflewire collects, by itself or through third parties, there are: Tracker; Usage Data; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); first name; last name; phone number; company name; email address; website; username; Camera permission; Approximate location permission (non-continuous); Phone permission; Storage permission; Social media accounts permission; Photo Library permission; Call permission; various types of Data; payment info; billing address; purchase history; geographic position; password; profession; profile picture; physical address; country; state; county; picture; city; Data communicated while using the service.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Shufflewire.
Unless specified otherwise, all Data requested by Shufflewire is mandatory and failure to provide this Data may make it impossible for Shufflewire to provide its services. In cases where Shufflewire specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Shufflewire or by the owners of third-party services used by Shufflewire serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Shufflewire and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Shufflewire (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Traffic optimisation and distribution, SPAM protection, Advertising, Analytics, Displaying content from external platforms, Commercial affiliation, Contacting the User, Content commenting, Device permissions for Personal Data access, Handling payments, Hosting and backend infrastructure, Infrastructure monitoring, Interaction with data collection platforms and other third parties, Interaction with external social networks and platforms, Location-based interactions, Managing contacts and sending messages, Registration and authentication, Registration and authentication provided directly by Shufflewire and Social features.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Device permissions for Personal Data access

Depending on the User's specific device, Shufflewire may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependant on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of Shufflewire.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Shufflewire.

Approximate location permission (non-continuous)

Used for accessing the User's approximate device location. Shufflewire may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for Shufflewire to derive the approximate position of the User on a continuous basis.

Call permission

Used for accessing a host of typical features associated with telephony.

Camera permission

Used for accessing the camera or capturing images and video from the device.

Phone permission

Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.

Photo Library permission

Allows access to the User's Photo Library.

Social media accounts permission

Used for accessing the User's social media account profiles, such as Facebook and Twitter.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Advertising

  This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Shufflewire, possibly based on User interests.
  This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
  Some of the services listed below may use Trackers to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside Shufflewire. For more information, please check the privacy policies of the relevant services.
  Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

  Google AdSense (Google Ireland Limited)

  Google AdSense is an advertising service provided by Google Ireland Limited. This service uses the “DoubleClick” Cookie, which tracks use of Shufflewire and User behaviour concerning ads, products and services offered.
  Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

  In order to understand Google's use of data, consult Google's partner policy.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Google Ad Manager (Google Ireland Limited)

  Google Ad Manager is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
  In order to understand Google's use of data, consult Google's partner policy.
  This service uses the “DoubleClick” Cookie, which tracks use of Shufflewire and User behaviour concerning ads, products and services offered.  

  Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

• Analytics

  The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

  Google Analytics (Google Ireland Limited)

  Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilises the Data collected to track and examine the use of Shufflewire, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Google Analytics Advertising Reporting Features (Google Ireland Limited)

  Google Analytics on Shufflewire has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyse specific behaviour and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).

  Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

  Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Google Analytics Demographics and Interests reports (Google Ireland Limited)

  Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for Shufflewire (demographics means age and gender Data).

  Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

  Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

  Place of processing: Ireland – Privacy Policy – Opt Out.

• Commercial affiliation

  This type of service allows Shufflewire to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
  Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with Shufflewire.
  For details of which data are collected, please refer to the privacy policy of each service.

  Awin (AWIN AG)

  Awin is a commercial affiliation service provided by AWIN AG.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Germany – Privacy Policy.

  CJ Affiliate by Conversant (Conversant LLC)

  CJ Affiliate by Conversant is a commercial affiliation service provided by Conversant, Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Amazon Affiliation

  Amazon Affiliation is a commercial affiliation service provided by Amazon.com Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy; Luxembourg – Privacy Policy.

  TradeDoubler

  Tradedoubler is a global affiliate marketing network with 20 years of expertise in digital marketing innovation. Our market-leading technology platform enables us to offer tailored performance solutions based on your exact needs – all over the world!

  Partnerize

  Partnerize delivers the software platform and expert service that help the world’s leading brands create operating leverage by turning their partnerships channels into profit centers.

• Contacting the User

  Contact form (Shufflewire)

  By filling in the contact form with their Data, the User authorises Shufflewire to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

  Personal Data processed: company name; email address; first name; last name; phone number; website.

  Mailing list or newsletter (Shufflewire)

  By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Shufflewire. Your email address might also be added to this list as a result of signing up to Shufflewire or after making a purchase.

  Personal Data processed: email address; first name; last name.

  Phone contact (Shufflewire)

  Users that provided their phone number might be contacted for commercial or promotional purposes related to Shufflewire, as well as for fulfilling support requests.

  Personal Data processed: phone number.

• Content commenting

  Content commenting services allow Users to make and publish their comments on the contents of Shufflewire.
  Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
  If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

  Comment system managed directly (Shufflewire)

  Shufflewire has its own internal content comment system.

  Personal Data processed: email address; first name; last name; Usage Data; username.

• Device permissions for Personal Data access

  Shufflewire requests certain permissions from Users that allow it to access the User's device Data as described below.

  Device permissions for Personal Data access (Shufflewire)

  Shufflewire requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.

  Personal Data processed: Approximate location permission (non-continuous); Call permission; Camera permission; Phone permission; Photo Library permission; Social media accounts permission; Storage permission.

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of Shufflewire and interact with them.
  This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Font Awesome (Fonticons, Inc. )

  Font Awesome is a typeface visualisation service provided by Fonticons, Inc. that allows Shufflewire to incorporate content of this kind on its pages.

  Personal Data processed: Usage Data.

  Place of processing: United States – Privacy Policy.

  Mapbox widget (Mapbox Inc.)

  Mapbox is a maps visualisation service provided by Mapbox Inc. that allows Shufflewire to incorporate content of this kind on its pages.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  SoundCloud widget (SoundCloud Limited)

  Soundcloud is an audio content delivery service provided by SoundCloud Limited that allows Shufflewire to incorporate content of this kind on its pages.

  Personal Data processed: Usage Data.

  Place of processing: Germany – Privacy Policy.

  Spotify widget (Spotify AB)

  Spotify is an audio content delivery service provided by Spotify AB that allows Shufflewire to incorporate content of this kind on its pages.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Sweden – Privacy Policy.

  Video Vimeo (Vimeo, LLC)

  Vimeo is a video content visualisation service provided by Vimeo, LLC that allows Shufflewire to incorporate content of this kind on its pages.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  YouTube video widget (Google Ireland Limited)

  YouTube is a video content visualisation service provided by Google Ireland Limited that allows Shufflewire to incorporate content of this kind on its pages.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

• Handling payments

  Unless otherwise specified, Shufflewire processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Shufflewire isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

  Stripe ( Stripe Technology Europe Ltd)

  Stripe is a payment service provided by Stripe Inc.

  Personal Data processed: billing address; email address; first name; last name; payment info; purchase history; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  WooCommerce Payments

  WooCommerce Payments is a fully integrated solution that empowers you to monitor charges, handle disputes, track deposits, and keep tabs on recurring revenue from inside your store – leaving you with more time to focus on growing your business.

  PayPal (PayPal Inc.)

  PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

  Personal Data processed: billing address; email address; first name; last name.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable Shufflewire to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Shufflewire.

  Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  SiteGround Hosting (SiteGround Hosting Ltd.)

  SiteGround Hosting is a hosting service provided by SiteGround Hosting Ltd.

  Personal Data processed: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United Kingdom – Privacy Policy.

  iubenda Consent Solution (iubenda srl)

  The iubenda Consent Solution allows to store and retrieve records of final Users’ consent to the processing of Personal Data, and preferences thereof.

  Personal Data processed: Data communicated while using the service; Tracker.

  Place of processing: Italy – Privacy Policy.

• Infrastructure monitoring

  This type of service allows Shufflewire to monitor the use and behaviour of its components so its performance, operation, maintenance and troubleshooting can be improved.
  Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Shufflewire.

  Uptime Robot (Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.)

  Uptime Robot is a monitoring service provided by Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Turkey – Privacy Policy.

• Interaction with data collection platforms and other third parties

  This type of service allows Users to interact with data collection platforms or other services directly from the pages of Shufflewire for the purpose of saving and reusing data.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

  Mailchimp widget (The Rocket Science Group LLC)

  The Mailchimp widget is a service for interacting with the Mailchimp email address management and message sending service provided by The Rocket Science Group LLC.

  Personal Data processed: email address; first name; last name.

  Place of processing: United States – Privacy Policy.

• Interaction with external social networks and platforms

  This type of service allows interaction with social networks or other external platforms directly from the pages of Shufflewire.
  The interaction and information obtained through Shufflewire are always subject to the User’s privacy settings for each social network.
  This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
  It is recommended to log out from the respective services in order to make sure that the processed data on Shufflewire isn’t being connected back to the User’s profile.

  Facebook Like button and social widgets (Facebook Ireland Ltd)

  The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook Ireland Ltd

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  LinkedIn button and social widgets (LinkedIn Corporation)

  The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Pinterest “Pin it” button and social widgets (Pinterest, Inc.)

  The Pinterest “Pin it” button and social widgets are services allowing interaction with the Pinterest platform provided by Pinterest Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Reddit button and widgets (reddit inc.)

  The reddit button and widgets are services allowing interaction with the reddit platform provided by reddit inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Twitter Tweet button and social widgets (Twitter, Inc.)

  The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

• Location-based interactions

  Non-continuous geolocation (Shufflewire)

  Shufflewire may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorisation has been provided, the User’s location data may be tracked by Shufflewire.
  The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.

  Personal Data processed: geographic position.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  Mailchimp (The Rocket Science Group LLC)

  Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.

  Personal Data processed: email address; first name; last name.

  Place of processing: United States – Privacy Policy.

• Registration and authentication

  By registering or authenticating, Users allow Shufflewire to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, Shufflewire will be able to access some Data, stored by these third-party services, for registration or identification purposes.
  Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

  Facebook Authentication (Facebook Ireland Ltd)

  Facebook Authentication is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Facebook social network.

  Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy.

  Google OAuth (Google Ireland Limited)

  Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy.

  Facebook Oauth (Facebook Ireland Ltd)

  Facebook Oauth is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Facebook social network.

  Personal Data processed: Tracker; various types of Data.

  Place of processing: Ireland – Privacy Policy.

• Registration and authentication provided directly by Shufflewire

  By registering or authenticating, Users allow Shufflewire to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

  Direct registration (Shufflewire)

  The User registers by filling out the registration form and providing the Personal Data directly to Shufflewire.

  Personal Data processed: company name; email address; first name; last name; password; profession; profile picture; username.

• Social features

  Public profile (Shufflewire)

  Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with Shufflewire.

  Personal Data processed: city; company name; country; county; email address; first name; geographic position; last name; phone number; physical address; picture; profession; state; username.

• SPAM protection

  This type of service analyses the traffic of Shufflewire, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.

  Google reCAPTCHA (Google Ireland Limited)

  Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

  Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  CleanTalk

  CleanTalk Anti-Spam is a cloud service protection from spam for websites. CleanTalk uses protection methods that are invisible to site visitors. Connection to the service eliminates the need for Captcha, questions and answers and other methods of protection, that complicate the exchange of information on the website.

• Traffic optimisation and distribution

  This type of service allows Shufflewire to distribute their content using servers located across different countries and to optimise their performance.
  Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Shufflewire and the User's browser.
  Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

  Cloudflare (Cloudflare Inc.)

  Cloudflare is a traffic optimisation and distribution service provided by Cloudflare Inc.
  The way Cloudflare is integrated means that it filters all the traffic through Shufflewire, i.e., communication between Shufflewire and the User's browser, while also allowing analytical data from Shufflewire to be collected.

  Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

• Equal protection of User Data

  Shufflewire shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.

• Global TCF v2 Cookie (euconsent-v2)

  Global TCF v2 Cookie (euconsent-v2) stores User advertising tracking preferences under the .consensu.org domain. When a Global TCF v2 Cookie (euconsent-v2) is set by the iubenda Cookie Solution, also a local 'cache' Cookie is stored in the local domain.

• Push notifications

  Shufflewire may send push notifications to the User to achieve the purposes outlined in this privacy policy.

  Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for Shufflewire, some or all of the apps on the particular device.
  Users must be aware that disabling push notifications may negatively affect the utility of Shufflewire.

• Rights for registered California Users under the age of 18

  California's "Online Eraser" law, part of California's Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.

  If a registered User fits that description and posted content on Shufflewire, they may request removal of such content by contacting the Owner or its privacy policy coordinator at the contact details provided in this document.

  In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner's servers. It may also be publicly available elsewhere if a third party copied and reposted this content.

• Selling goods and services online

  The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
  The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Shufflewire depends on the payment system used.

• Site specific TCF v2 Cookie (euconsent-v2)

  Site specific TCF v2 Cookie (euconsent-v2) stores User advertising tracking preferences in the local domain.

• The Service is intended for adults

  Users declare themselves to be adult according to their applicable legislation. Minors may not use Shufflewire.

• iubenda CCPA Cookie (usprivacy)

  iubenda CCPA Cookie (usprivacy) is set by the iubenda Cookie Solution and stores California consumer opt-out choices in the local domain.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

Shufflewire uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Shufflewire or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Shufflewire may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Shufflewire and any third-party services may collect files that record interaction with Shufflewire (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Shufflewire does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Shufflewire and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.