SURFSHOTS PRIVACY POLICY

Last updated: September 5, 2023

Surfshots, and its affiliates, (collectively, “Surfshots”) is committed to protecting your privacy. This privacy policy tells you about our collection, use, and disclosure of your personal data. The terms of this policy apply to all Surfshots websites, applications and associated services that link to this privacy policy (the “websites”), it does not apply to websites or services that link to a different privacy notice.

Consent

If You continue to use our website or services and/or submit your personal information to Surfshots, you consent to the purposes and uses outlined below for which Surfshots collects and/or shares your personal information.

Collection of Your Personal Information

The personal data we collect depends on how you interact with us, the websites you use, and the choices you make. We collect and process personal data about you with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.

Information you provide directly: We collect personal information you provide to us. For example, we collect your name, email address, postal address, phone number, fax number, demographics, and other information you provide us. If you make a purchase, we also collect credit card numbers and other payment information.

Information collected automatically: Surfshots collects certain kinds of information, such as the website that referred you to us, your IP address, browser type and language, and access times. We also may collect navigational information, including information about the pages you view, the links you click, and other actions taken in connection with the site. We also collect further information as discussed below under “Use of Cookies and Other Technologies”.

Third-party sources: We also obtain information from third parties. We protect information obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of the information.

These third-party sources include:

• Data brokers from which we purchase demographic data to supplement the data we collect;
• Applications and services, such as social networks, that make users' information available to others;
• Service providers that help us determine your device's location based on its IP address to customize certain products to your location;
• Partners with which we offer co-branded services or engage in joint marketing activities; and
• Publicly available sources, such as open government databases or other data in the public domain.

We may combine your personal data collected across the above sources.

We use the term "devices" to refer collectively to computers and mobile devices, as well as the internet browsers and other applications on your devices that interact with the internet. Surfshots engages in cross-device data collection, which refers to the process of collecting data from devices that have been determined through statistical analysis to be linked or related. Our partners whom we employ to provide this service use cross-device data to provide interest-based advertising services to our customers and to deliver tailored ads to users across multiple devices.

Use of Your Personal Data

Surfshots uses your personal data collected through our websites for purposes described in the privacy policy or otherwise disclosed to you.

For example, we use your personal data to:

• provide and deliver services, including securing, troubleshooting, improving, and personalizing those products;
• operate and improve our websites and business, including our internal operations and security systems;
• understand you and your preferences to enhance your experience using our websites;
• process your transactions;
• provide customer service and respond to your questions;
• perform research and analysis aimed at improving our products, services, and technologies;
• send you information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
• communicate with you about new products, offers, promotions, rewards, contests, upcoming events, and other information about our products and those of our selected partners; and
• display content, including advertising, that is customized to your interests and preferences.

In carrying out these purposes, we combine data we collect from different sources to give you a more seamless, consistent, and personalized experience.

Sharing of Your Personal Data

Except as disclosed in this privacy policy, Surfshots does not share your personal data with any outside parties.

We share personal data with your consent or as necessary to complete your transactions or provide the products or services you have requested or authorized. We may also share your personal data within our corporate group, including with our subsidiaries, affiliates, and divisions, all of whom may use your data for the purposes disclosed herein. In addition, we may share your personal data with our approved and appointed distributor network.

We may share your personal data with service providers who perform services on our behalf. For example, we may hire other companies to handle the processing of payments, to provide data storage, to host websites, to fulfill orders and shipments, to assist in direct marketing, analyze your interests and preferences, and to conduct audits, etc. Those companies will be permitted to obtain only the personal data they need to provide the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose. Surfshots maintains contracts with these third parties requiring their treatment (access, use, and disclosure) of personal data to be consistent with our obligations under the law.

Information about our customers, including personal data, may be disclosed as part of any merger, transfer, divestiture, acquisition, or sale of all or a portion of the company and/or its assets, as well as in the unlikely event of insolvency, bankruptcy, or receivership, in which personal data would be transferred as one of the business assets of the company.

We reserve the right to disclose your personal data if we have a good faith understanding we are required to do so by law (including to meet national security or law enforcement requirements), or in the good-faith belief that such action is reasonably necessary to comply with legal process, respond to claims, or protect the rights, property, or safety of our company, employees, customers, or the public.

Retention of Personal Data

We retain personal data for as long as necessary to provide the products and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.

Social Media

On some pages, we allow you to share personal data with third parties, such as social networks. In these instances, you are agreeing to the data being shared and the shared data is subject to the privacy policies of such third parties. We may combine information we receive from those platforms (e.g., profile information, likes, pageviews) with other information we collect from you or other sources and use and disclose it as described in this privacy policy. We do not control and do not assume any responsibility for the use of personal data by such third parties. For more information about the third party's purpose and scope of their use of personal data in connection with sharing features, please visit the privacy policies of these third parties.

Use of Cookies and Other Technologies

Surfshots uses "cookies" and other technologies like pixel tags, web beacons, and similar technologies to enable you to sign in to our services and to help personalize and improve your online experience. A cookie is a small text file that is placed on your hard drive or device. Cookies contain information, including personal data that can later be read by a web server in the domain that issued the cookie to you. We may use web beacons to help deliver cookies.

Analytics

Our websites may include cookies from third-party service providers. This is because we have hired third parties to provide services on our behalf, such as site analytics. For this purpose, Surfshots works with various third-party partners to track your actions on third-party websites and deliver personalized ads to you via those websites.

Third Party Advertising

We allow third parties to use cookies for advertising purposes. Our web pages may contain content or ads from third parties, and those third parties may set or read their own cookies on your device. They may also collect information about your online activities across websites or online services. We also work with third-party partners to show their advertisements to you on our and third-party websites.

Security of Your Personal Data

The security of your personal data is important to us. We take appropriate and reasonable steps to help protect your personal data from unauthorized access, use, disclosure, alteration, and destruction. However, we cannot guarantee its absolute security. If a password is used to protect your account and personal data, it is your responsibility to keep your password confidential.

Links

We may link to websites, including those of our third-party content providers or distributor network, that have different privacy policies and practices from those disclosed here. We assume no responsibility for the policies or practices of such linked sites and encourage you to become acquainted with them prior to use.

Changes to This Privacy Policy

We reserve the right to change the terms of this privacy policy at any time to reflect changes in our products, how we process personal data, or applicable law. When we make changes, we will revise the "last updated" date at the top of the policy. If there are material changes to this statement, we will provide notice or obtain consent regarding such changes as may be required by law. We encourage you to review this policy whenever you visit one of our sites.

Accessing Your Personal Data

If you would like to review or revise information that you previously provided to us, you may access your information in the "Your Settings" section of the website. We can also assist you in making any changes, as well as in exercising your right to have your personal data deleted. If you need additional assistance, have any questions about our privacy policy, how user information is stored, or the record of your visit to our website, please email us at admin@surfshots.app.