PLATFORM’S PRIVACY POLICY

This Privacy Policy (“Privacy Policy”) outlines Stratford Ltd. (“Company” “we” “us” or “our”) data collection practices that are applicable toward: (ii) any visitor of our Website (“Visitor”) available at: https://shelfy.io/ ; (ii) our customers and their authorized users (i.e., their employees) (“Merchants”); and (iii) the Mobile Store end users (“End User”).

Visitors, Merchants and End Users shall be collectively referred to herein as “you” or “your“. 

This Privacy Policy is an integral part of our Terms of Service (“Terms“) which includes additional information and conditions regarding our Service (as such term is defined therein). Any capitalized terms used herein but not defined herein shall have the meaning ascribed to them in the Terms.

If you have any questions regarding this Privacy Policy or our data practices, you are welcome to contact us at: contact@shelfy.io.

For the purposes of the European Union General Data Protection Regulation (“GDPR“), we are considered the Controller (as such term is defined under the GDPR) of the Personal Data we collect from the Visitors and Merchants, and considered the Processor (as such term is defined under the GDPR) of the Personal Data that we collect from End Users.  

In the event you are a California resident and the CCPA applies to you – please also review Exhibit A (CCPA Privacy Exhibit).

  1. INFORMATION PROCESSED BY THE COMPANY

We may collect two types of data and information from you, depending on your interaction with us. The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from whom we have collected the Non-Personal Data. Non-Personal Data which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, your action in the Website or Services (such as session duration and page impressions), or approximate geo-location. 

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”). 

For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

Personal Data we collect from Visitors:

Type of DataPurposes of ProcessingFor EU persons – Legal Basis under the GDPR
Contact Information:In the event you contact us (i.e., to get a price quote, book a demo or in need of support), you may be required to provide us with your full name, email address, phone number, your company name etc.
We will use this information solely for the purpose of responding to your inquiries and provide you with the support or information you have requested. 
Our legitimate interest.
Career In the event you apply for a job via our Website, we will process your CV (and the information included therein), your cover letter as well as additional information such as your contact information (name, email address and phone number).To process your job application and for recruitment purposes.Our legitimate interest.
Newsletter:If you voluntarily subscribe to our newsletter, you will be asked to provide us with your email address. You can unsubscribe at any time using the unsubscribe option within the body of the newsletter or by contacting customer support at [contact@shelfy.io].We will use your email address solely in order to provide you with the content that you requested to receive.Your consent. 
Online IdentifiersWhen you use our Services, we will collect your Internet Protocol (“IP”) address. This data may be collected by us or by our third-party service providers as further explained below in the cookie clause.We will use this information in order to maintain, protect and manage the Website and for analytical and statistical purposes regarding traffic flow, your interaction with our Website and for marketing purposes Your consent. 

Information We Collect from Merchants:

Type of DataPurposes of ProcessingFor EU persons – Legal Basis under the GDPR
Account RegistrationIn order to use our Services, you will be required to register and open an account. During the registration process we will collect certain information such as your full name, physical address, email address, payment information, etc.To provide the Services to the Merchant. 





Performance of a contract with you or in order to take steps at your request prior to entering into a contract.
Direct Marketing As our customer we will send you invoices, reports and marketing materials regarding the Services you are currently using or any services we may offer in the future (“Direct Marketing”).  You are able to unsubscribe from receiving such correspondence from us by clicking on the designated link in the applicable message that we will send you or by contacting us at: contact@shelfy.io.
Please note that if you choose to unsubscribe from our Direct Marketing, we may still retain your contact details and send you relevant service-related information.
We will process this information subject to our legitimate interest.
Payment Details:In the event the payments of the Service Fees are paid directly by Merchant to Company, we will process certain payment information. We use third party payment processors to process this information. Consequently, any transactions that are processed by these third-party payment processors will be governed by their privacy policies and terms which we recommend that you review. Performance of a contract with you. 

Information we collect from End Users:

Log in: When the End User logs in either through the Ecommerce Platform or through your Facebook, Google+ or Apple account, we will process certain information such as your ID, name and may process information you made public through such platform. We will use this data for the purpose of providing our Services and designate your account. Your contact details will be used in order to send you needed information related to our Services. In addition, it will be used for additional occasional communications and updates related to the Services, as well as promotional and marketing emails. We act as the processor when we collect and process this type of data, which is processed on behalf of our customer.Performing our contract with you 
Shopping HistoryWhen you access or use the Mobile Shop, we will collect and process your Mobile Shop and Web Shop’s shopping related data (such as purchased products, date of purchase, quantities, prices, time spent on a specific product (sku), abandoned basket, etc.) (“Shopping History”).  In addition, we will use this data as part of providing the services to the Merchant including providing promotional and marketing activates on its behalf, such as providing end user with relevant offers.  We will use this data for the purpose of performing research, and conducting analytical analysis.
 In addition, we will use this data for promotional and marketing purposes, such as providing End Users with relevant offers. We act as the processor when we collect and process this type of data, which is processed on behalf of our customer (the Merchant)
We process this on behalf of our customers (the Merchants) as a processor/service provider, therefore, we rely on the lawful basis established by our customers 

 
  1. HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with us, we may collect information from you in one or both of the following ways:

  1. Automatically – we may use cookies (as further elaborated below) or other similar tracking technologies to gather some information automatically when you interact with our Website and Service.
  2. Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through the Service, when you contact us or sign up for our newsletter.
  1. SHARING DATA WITH THIRD PARTIES

We will not share your Personal Data with third parties, other than as specifically mentioned herein:

  1. Compelled Disclosures – To satisfy any applicable law, regulation, legal process, subpoena or governmental request; 
  2. Enforcement of our Rights – To enforce this Privacy Policy and the terms of our agreements (including the Terms), including the investigation of potential violations thereof; 
  3. Security Detections – To detect, prevent, or otherwise address fraud, security or technical issues; 
  4. Business Transfers and Affiliated Companies – When it is undergoing any change in control, including by means of a merger, acquisition or purchase of all or substantially all of its assets or with our parent company, any subsidiaries, joint ventures, or other companies under common control with the Company solely if and when applicable or necessary for the purposes described in this Privacy Policy, or in the event of any of the corporate transactions listed herein; 
  5. Service Providers – To collect, hold or manage your Personal Data through our authorized third-party service providers and to perform certain requested services on our behalf, as reasonable for our business purposes, all of whom we contractually ensure comply with applicable data protection laws. Some examples of service providers that we may use include (without limitation): payment processors, , server and storage providers and marketing partners;
  6. Explicit Consent – If you provide us with your explicit approval to share your information prior to the disclosure.
  1. COOKIES & TRACKING TECHNOLOGIES

We or our third-party service providers may use cookies and other similar tracking technologies or methods of web and mobile analysis to gather, store, and track certain information related to your access of, activity and interaction with our Service.   

A “cookie” is a small piece of information that a website assigns to your device while you access such website. Cookies are very helpful and may be used for a variety of different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Service quicker, easier and smoother. Cookies are also used to help customize your experience and for advertising purposes (including personalized advertising). You can find out more information about cookies at www.allaboutcookies.org.

The third-party cookies used on our Website are as follows: [Shelfy: please provide us a list third-party cookies used on our Website (such as Double click)] 

CookiePurposePrivacy Policy
Google Analytics Analytical, Measurement & Performance www.google.com/policies/privacy/partnershttps://policies.google.com/technologies/managing?hl=en  https://tools.google.com/dlpage/gaoptoutFor additional information regarding our use of Google products, click here.
Firebase Analytical, Measurement & Performance https://firebase.google.com/support/privacy#firebase_data_processing_and_security_terms
  

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience may be limited.

Please see the following links for more information with respect to how you can block or erase cookies via your particular browser: Google Chrome; Firefox; Internet Explorer; Safari; Edge; Opera.

  1. USER RIGHTS 

Depending on your jurisdiction, data protection and privacy laws provide you with the ability to exercise certain rights regarding your Personal Data that we process. Please note that, unless you instruct us otherwise, we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements. If you object to the aforesaid collection, use and sharing of data, please immediately cease using the Services and/or Platform. 

Where provided under applicable law (such as, within the European Union), you may have the right to ask us to delete Personal Information, subject to applicable exceptions, such as in order to preserve that information for anticipated litigation or demands from a regulator, or some or all of the following rights: the right to obtain information on our use of your Personal Data, the right to obtain a copy thereof, the right of data rectification, the right to data portability, the right to object to processing based on our legitimate interests, the right to restriction of the processing, and the right to withdraw your consent.

Important to note that Shelfy is not responsible for content shown or data collected on the merchant’s website.

To assert any of these rights, please contact us at: [contact@shelfy.io]. Note that we may request proof of identity, and we reserve the right to charge a fee where allowed by law, such as in circumstances where your request is excessive. In addition, you may have the right to lodge a complaint with a supervisory authority, subject to applicable law (as is the case in the European Union).

  1. DATA RETENTION

We retain Personal Data for as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws or until an individual requests to opt-out of such collection, subject to applicable laws. We may at our sole discretion, delete or amend information from our systems, without providing any notice to you, once we deem it is no longer necessary for our purposes.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice of our intention to do so.

  1. SECURITY 

We take great care in implementing and maintaining the security of your Personal Data. We employ industry standard procedures and policies to ensure the safety of individuals’ information and prevent unauthorized use of any of such. We have implemented technical, physical and administrative security measures to protect your Personal Data. Please review our Information Security Policy to learn more regarding our security practices. 

Please contact us at: contact@shelfy.io if you believe that your privacy was treated in a way that was not in accordance with this Privacy Policy. In the event of a security incident in which we discover that your Personal Data may be at risk, we will take reasonable efforts to notify you and the applicable authority (if we are required to do so, subject to applicable laws).

  1. DATA TRANSFER

We may store or process your Personal Data in the EU, the United States or in other countries. In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Furthermore, when Personal Data that is collected within the European Economic Area (“EEA“) is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union. If you would like to understand more about these arrangements and your rights in connection therewith, please contact us at: [contact@shelfy.io] and review our Information Security Policy for more information.  

  1. CHILDREN 

The Website and our Service are not intended for use by children (the phrase “child” shall mean an individual that is under the age defined by applicable law which with respect to the European Economic Area (“EEA“) is under the age of 16 and with respect to the U.S.A, under the age of 13) and we do not knowingly process a children’s information. We will discard any information that we receive from a user that is considered a “child” immediately upon our discovery that such a user shared information with us. Please contact us at: [contact@shelfy.io], if you have reason to believe that a child has shared any information with us. 

  1. CHANGES AND UPDATES

We reserve the right to amend this Privacy Policy at any time. As such we recommend that you re-visit this page frequently and review the Privacy Policy for any changes that we may have made. In the event that we made any substantial changes to this Privacy Policy, we will make reasonable efforts to provide you with notification with respect to such changes, if we are required to do so by applicable law. The changes to this Privacy Policy will go into effect as of the date listed in the “Last Amended” heading located at the top of this Privacy Policy. 

  1. CONTACT US

If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us: 

By Email: contact@shelfy.io

By mail: To: 

Stratford, Ltd

18 Raul Valenberg Street, Tel Aviv, Israel

EXHIBIT A 

CCPA PRIVACY EXHIBIT

  1. INTRODUCTION

This CCPA Privacy Exhibit (“Exhibit”) governs the manner in which we process information collected from Merchants and Visitors who reside in the State of California (“Consumers” as defined under the CCPA, and will be referred to herein as “you”). Any terms defined in the CCPA have the same meaning when used in this Exhibit. Furthermore, this Exhibit is an integral part of our Privacy Policy and thus, definitions used herein but not defined herein shall have the meaning ascribed to them in our Privacy Policy.

To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.

  1. CATEGORIES OF PERSONAL INFORMATION

When you access our Website and use our Service, we collect certain data regarding such use. This data includes “Personal Information” that is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device as detailed in the table below. 

Please see below a table detailing the categories of Personal Information that we collect (and have collected within the last 12 months):

CategoryExamples of Personal Information Collected
A. Identifiers.A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some personal information included in this category may overlap with other categories.Yes
C. Protected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).No
D. Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No
E. Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.No
F. Internet or other similar network activity.Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.Yes 
G. Geolocation data.Physical location or movements.No
H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.No
I. Professional or employment-related information.Current or past job history or performance evaluations.No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.No
K. Inferences drawn from other personal information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.No
  1. DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose: 

Category A: Identifiers;

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));

Category D:  Commercial information.

Category F:  Internet or other similar network activity.

We disclose your Personal Information for a business purpose to the following categories of third parties: data aggregators, service providers (e.g., servers etc.) and business partners. 

When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

  1. SALE OF PERSONAL INFORMATION

In the preceding twelve (12) months, we have not sold Personal Information

As required under the CCPA, we will update our Privacy Policy every 12 months. The last revision date will be reflected in the “Last Amended” note located at the bottom of this Privacy Policy. 

Last Amended: January 30, 2022

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