This Privacy Policy describes the data protection practices of Original Shift, Inc. (“Original Shift,” “we,” “us,” or “our”). This Privacy Policy applies to information that we collect and use about you when you access or use the Original Shift website, or other online or offline services that link to or otherwise present this Privacy Policy to you. We refer to these websites and services collectively as the “Services.”

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

This Privacy Policy contains the following sections:

  • The Information We Collect
  • How We Use Your Information
  • Legal Bases for Use of Your Information
  • Cookies and Similar Technologies
  • Online Analytics and Advertising
  • How We Share and Disclose Your Information
  • Retention of Your Information
  • Individual Rights and Choices
  • Third Party Links and Features
  • International Users
  • How We Protect Your Information
  • Privacy Information for California Residents
  • Privacy Information for Nevada Residents
  • Changes to Our Privacy Policy
  • Contact Information

 

THE INFORMATION WE COLLECT

We obtain information about you through the means discussed below when we provide the Services.

1. INFORMATION YOU PROVIDE TO US

We collect a variety of information that you provide directly to us, for example, through:

  • The Services you use
  • Requests or questions you submit to us via online forms, email, or otherwise
  • Your participation in sweepstakes, contests, or surveys
  • Your application for a job with us
  • Uploads or posts to the Services

The types of data we collect directly from you includes:

  • Email address
  • First and last name
  • Billing information, such as financial account number, verification number, expiration date, and similar information
  • Information you provide in connection with an employment application, such as your resume, position, business address, business phone number, and business email address
  • Information about your customer service interactions with us
  • Information provided in your responses to surveys we conduct

2. INFORMATION WE COLLECT THROUGH AUTOMATED MEANS

When you use our Services, we collect certain information as described in this Section. As discussed further below, we and our service providers (which are third party companies that work on our behalf), may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.

Specifically, when you use our Services, we collect and analyze information such as your IP address, browser types, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes, referring and exit pages and URLs, the number of clicks, files you download, pages viewed and the order of those pages, the date and time you used the Services, error logs, and other similar information.  We also may automatically collect general location information (e.g., IP address, city/state and or postal code associated with an IP address) from your computer or mobile device.

3. INFORMATION WE COLLECT FROM OTHERS

We may receive additional information such as demographic and statistical information from third parties, such as business partners, marketers, and analysts that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you and improve our products, analytics, advertising, and products.

 

HOW WE USE YOUR INFORMATION

We use your information for various purposes depending on the types of information we have collected from and about you, in order to:

  • Provide the Services you have requested or process your application for employment
  • Respond to your request for information and provide you with more effective and efficient customer service
  • Contact you by email, postal mail, or phone regarding Original Shift and third-party products, services, surveys, promotions, special events and other subjects that we think may be of interest to you
  • Customize the content you see on the Services
  • Help us better understand your interests and needs, and improve the Services, including through research and reports, and test and create new products, features, and services
  • Secure our Services and resolve technical issues being reported
  • Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
  • Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others

Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

Aggregate/De-Identified Data. We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device. We may use such information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

 

LEGAL BASES FOR USE OF YOUR INFORMATION

The legal bases for using your information as set out in this Privacy Policy are as follows:

  • Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with our Terms of Use)
  • Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our Services; operate our business and our Services; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud and to know the customer to whom we are providing Services)
  • Where we have a reason to process the data in accordance with applicable laws
  • Where we have your consent to engage in a particular data processing activity

 

COOKIES AND SIMILAR TECHNOLOGIES

To collect the information in the “Information We Automatically Collect” section above, we use cookies, tracking pixels, and other similar tracking technologies. We use these technologies in order to offer you a more tailored experience, by understanding and remembering your particular browsing preferences.  Cookies are small text files that are placed on your computer or mobile device when you visit a website, that enable us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. As we adopt additional technologies, we may also gather information through other methods.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet ExplorerGoogle ChromeMozilla Firefox; or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.

 

ONLINE ANALYTICS AND ADVERTISING

1. ANALYTICS

We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.  If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

2. ONLINE ADVERTISING

When you use the Services, advertising technology companies may place cookies or similar tools on your computer, mobile phone, or other device to collect information about your use of the Services. These third parties may use this information to serve relevant content and advertising to you as you use the Internet, and access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services to assist in this activity.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the Services by such non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that if you exercise the choices above, you may still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.

3. NOTICE CONCERNING DO NOT TRACK

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here.

 

HOW WE SHARE AND DISCLOSE YOUR INFORMATION

Original Shift will share your information in the following ways:

  • Affiliates and Subsidiaries.We may share information we collect within the Original Shift family to provide services to you, ensure a consistent level of service, and enhance our products, services, and your customer experience.
  • Service Providers.We provide access to or share your information with select third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including sales, marketing, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing, and legal services.
  • Protection of Original Shift and Others.By using the Services, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce our Terms of Use, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Original Shift, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
  • Business Transfers.As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
  • Aggregate/De-Identified Information.From time to time, we may share Aggregate/De-Identified Information about use of the Services, such as by publishing a report on usage trends. The sharing of such data is unrestricted.

 

RETENTION OF YOUR INFORMATION

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

 

INDIVIDUAL RIGHTS AND CHOICES

You have certain rights with respect to your information as further described in this section.

1. YOUR LEGAL RIGHTS

If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact Information” section below at any time. Your local laws (e.g., in the EU or California) may permit you to request that we:

  • provide access to and/or a copy of certain information we hold about you
  • prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
  • update information which is out of date or incorrect
  • delete certain information which we are holding about you
  • restrict the way that we process and disclose certain of your information
  • transfer your information to a third-party provider of services
  • revoke your consent for the processing of your information

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

2. MARKETING COMMUNICATIONS

You may instruct us not to use your contact information to send you marketing communications by email, postal mail, or phone regarding services, promotions and special events that might appeal to your interests by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

 

THIRD PARTY LINKS

The Services contain links to third-party websites.  If you choose to use those links and interact with such third parties, please note that we are not responsible for the content or practices of such third parties. The collection, use, and disclosure of your information will be subject to the privacy policies of the third parties, and not this Privacy Policy.

 

INTERNATIONAL USERS

Original Shift operated in the United States and as a result, the information we collect may be stored in the United States.  By using the Services, you acknowledge and agree that your information may be transferred to, used, processed, or held by Original Shift in the United States and in other countries, including countries outside of your country of residence and used for purposes set out in this Privacy Policy.  In providing services to you, Original Shift may also subcontract the processing of your data to, or otherwise share your data with service providers that perform business functions on our behalf that are located in countries other than your country of residence. By providing us with your information, you acknowledge any such transfer, storage or use.  If you live in the EEA, United Kingdom, or Switzerland, please note that if we provide any information about you to any third-party information processors outside of these jurisdictions, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy. These measures include signing Standard Contractual Clauses in accordance with EU and other data protection laws to govern the transfers of such data.

If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.

 

HOW WE PROTECT YOUR INFORMATION

Original Shift takes technical and organizational security measures to protect the information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet transmission is ever fully secure or error free.

 

PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

 

A. Categories of personal information we collect

Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about our users. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. The categories we collect are: (1) identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as financial account data to process transactions); internet or other network or device activity (such as browsing history or Service usage); general geolocation information (e.g., your approximate location based on IP address); professional or employment related data (e.g., your business contact information); and demographic and statistical information (e.g., your age and interests).

 

B. How we source, use, and share these categories of personal information

For information about how we source, use, and share the personal information we collect, please see the following sections above in this Privacy Policy: “The Information We Collect,” “How We Use Your Information,” “How We Share and Disclose Your Information.”

Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. We do not engage in such activity and have not engaged in such activity in the past twelve months from the effective date of this Policy.

 

C. Your California Privacy Rights

As explained above in the “Individual Rights and Choices” section, if you are a California resident, you have the right to make certain requests with respect to your data (e.g., access and/or deletion), and we will fulfill those rights in accordance with our legal obligations.  Please use the contact information provided below to exercise these rights.

D. CA Shine the Light Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

 

PRIVACY INFORMATION FOR NEVADA RESIDENTS

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing us at the contact information provided below.  Please note we may take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

 

CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” included at the beginning of the document. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

 

CONTACT INFORMATION

If there are any questions regarding this privacy policy, you may contact us using the information below.

Original Shift, Inc.
2443 Fillmore St #380-6570
San Francisco, CA 94115
USA
webmaster@originalshift.com

Last Edited & Effective on 2020-02-11