Privacy Policy

PRIVACY POLICY

Last Updated November 22, 2021

This Privacy Policy (the “Policy”) describes how Shacknews Ltd. (“Shacknews,” “we,” “us,” or “our”) collects, uses, and discloses personal information you share with us, including, without limitation, through the website https://www.shacknews.com  (the “Website”) and on the Shacknews and Shackpets mobile applications (the Website together with all Shacknews controlled mobile and desktop applications collectively known as the “Platform”).

By using the Platform and any other widgets, tools, features, content (including without limitation uploading or accessing photos, videos or other media), services or options otherwise provided by Shacknews in connection with the Platform (collectively with use of the Platform, the “Services”), you agree to our collection and use of personal information in accordance with this Policy and our Terms of Use ^[a](“Terms“).

Various privacy laws and regulations from around the world require certain disclosures and give certain privacy rights to residents of their jurisdictions. While those laws do not apply universally, we believe it is important to provide the same basic privacy rights to everyone regardless of where you live. Thus, the rights described in this policy and the options referenced below may be used by anyone with whom we interact or from whom we collect personal information. Your rights can be summarized as follows:

• You can ask us what personal information we have about you.
• You can correct or change the personal information we maintain about you.
• You can delete the personal information we maintain about you

More information on each of these requests and how to make them is provided below.

Personal Information We Collect

For purposes of this Policy, personal information means any information about an identifiable individual. Not all information we collect is personal information under this definition. For example, information that has been de-identified or aggregated in a way that no longer allows identification of a particular person would not meet this definition. We may use this type of non-personal information to improve the services we provide to our users.

We may collect, store, and process personal information from the categories shown in the table below. Our listing of these categories does not mean that all categories or the examples listed in each category are collected about everyone who uses the Platform or that . We are providing a full list here in the spirit of transparency.

How We Collect Personal Information

We collect the categories of personal information listed above from various sources. This section lists and describes those sources.

Directly from you. You may be asked to provide personal information when you use the Platform in certain ways. This information may include:

• Account and Subscription Information . When you set up an account, you are required to provide information such as your name or alias and email address and setup a password for future access to password protected portions of the Platform. Additionally, when you sign up for a Mercury subscription you are required to provide additional information such as your first and last name, t-shirt size, and mailing address. You may also need to provide payment card information to our third-party payment processor Stripe, as discussed below.

• Shackpets Competition . Users who choose to enter their pet into competition on the Shackpets portion of the Platform will have to provide additional information including pet name, bio and photos.
• Additional Information . Additional information that you provide to us, including when you complete certain forms, post via Cortex, comment through the Chatty, upload or submit any content or other material via the Platform, request information or contact us with inquiries through the Platform or via email, or when you use other aspects of our services, may be collected and stored.

Indirectly from you . We may automatically collect personal information from you when you visit the Platform through the use of tracking technologies or by other passive means. This “passively collected” information helps us to improve our offerings and allows us to ensure the Platform works as designed and in a way that meets your expectations. Some examples of the sources of this passively collected personal information include:

• Viewing History and Preferences . When you use the Platform, we collect information about your use. For example, if you use the “Search” feature on our Website to find all stories that contain a particular word, we may collect information about that action, such as the search terms you utilize and the stories you select. Additionally, if you are logged into your account while on the Platform we track pageviews, interactions on Chatty posts, and other indicators of your usage as part of our daily Shacknews Carnage competition.
• Log Information . We may automatically record information that your browser or mobile device sends whenever you visit the Platform, and especially when you login. These logs may include information such as your web request, IP address, browser type, browser language, your computer operating system, your mobile device and mobile operating system, the name of your internet service provider or your mobile carrier, the date and time of your request, and one or more cookies that may uniquely identify your browser.

• Cookies and Similar Tracking Technologies . When you visit or access the Website, we may utilize cookies (small text files containing a string of characters sent to your computer) or similar tracking technologies that uniquely identify your browser to track your activity and hold certain information. Cookies can be necessary for site navigation and performance, or used for targeting or advertising. We use the following types of cookies:

• Strictly necessary cookies . These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website or make payments through the Website. You can set your browser to block or alert you about these cookies, but some parts of the Website may not work properly or at all.

• Analytical/performance cookies . These cookies allow us to recognize and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website operates, for example, by ensuring that users are finding what they are looking for easily.

• Preference cookies . These cookies are used to recognize you when you return to the Website. This enables us to personalize content for you and remember your preferences.
• Marketing cookies . These cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make the Website and the information displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Most web browsers accept cookies automatically but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. Please note that if you disable all cookies, you may not be able to use some features of the Website.

• Additional website analytics . Among other technologies, our Website uses certain features from the Google Marketing Platform, including Google Analytics to gather information about website usage. This information is anonymized, but is stored by Google on their servers and is used by us and them to evaluate our website activity and inform enhancements. Google may transfer this information to third party processors or when required to by law, but will not associate an IP address with any other data held by Google. By using this website, you are consenting to the processing of this kind of data by Google. For more details please refer to Google Analytics’ article, “ Safeguarding your data .”

From third parties . We may collect personal information about you from third parties, either at your request or for our business purposes. These third-party sources vary depending on your engagement with us, but could include the following:

• Social Media Technologies and Similar Third-Party Services . You can link your social media or other third-party account to Shacknews. By linking these services, you authorize us to collect, store and use any information they may give us as a result of that connection. You can disconnect your Shacknews account registration from these third-party accounts at any time. We also receive information from you when you interact with our pages, groups, accounts or posts on social media platforms. This includes aggregate data on our followers (e.g., age, gender and location), engagement data (e.g., “likes,” comments, shares, reposts and clicks), awareness data (e.g., number of impressions and reach) and individual users’ public profiles.

• Technical Service Providers . We work with a variety of third-party service providers to enhance the Platform and ensure it functions the way you expect. Our partners provide website hosting, website usage analytics, application development, advertising, and maintenance services. Many of the categories of data used by these providers overlap with the passively collected personal information described above. In working with our service providers, we may share personal information with them and receive personal information back from them so that we may provide the services you expect.

• Payment Processor Stripe . We use Stripe as our payment processor. Stripe provides us with an online solution to process Mercury subscriptions and other items for sale through the Platform. When you pay for services, your personal information, including payment card numbers and certain identifiers, are collected and stored by Stripe pursuant to their terms and procedures. Stripe stores data in a safe and secure manner with access limited to authorized personnel pursuant to the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored by Stripe only as long as is necessary to complete your purchase transaction. Shacknews does not see your full payment card number (only the last 4 digits) and does not store your payment information. PCI-DSS requirements help ensure the secure handling of payment card information.  For more information about Stripe’s terms and procedures, you may want to read Stripe’s privacy & terms  page.

We are not responsible for the privacy practices of third-party providers. By using our Website, you consent to the processing of your personal information by our third party service providers in the manner and for the purposes described here and in their privacy policies.

How We Use the Personal Information Collected

Shacknews has a rich history of providing accurate and up-to-date news and information on a variety of topics. We also pride ourselves in giving voice and a community to video game enthusiasts and others across the internet. To do this we use

both personal information and non-personal information to provide services to you, to help improve your interaction with the Platform, and to support our business or commercial purposes. Some examples of ways in which we use or disclose personal information include:

• To create and maintain your account.
• To identify you when you log in to the Platform
• To present the Chatty and to facilitate online communication among account holders.
• To respond to your questions or inquiries.
• To subscribe you to membership(s) you request.
• To process your purchases.
• To ask you to participate in surveys, or otherwise provide feedback.
• To notify you of new resources, products or offerings that might be of interest to you.
• To improve, upgrade or enhance the Platform and our services.
• To create de-identified or aggregated lists of information for any of the uses stated above.
• To operate the Website in accordance with our Terms^[b]  and/or any other agreement you may have with us.
• To carry out other purposes that are disclosed to you and/or to which you consent.

How We Share Personal Information

Shacknews does not and will not sell your personal information to third-parties in the conventional sense (i.e., for money). The ways in which we share personal information are generally described, as follows:

• Comments and discussion you post to the Chatty or articles you post via Cortex will be shared with other users of the Platform. We think this is self-evident, but out of an abundance of caution and in light of very broad interpretations of what must be disclosed to you in certain privacy laws, we are disclosing this information to you.

• Like many companies, we use services that help us deliver content to you that you will find interesting—sometimes that may include advertisements. Our third-party providers may need to receive some of your personal information in order to deliver this sort of interest-based content. Making personal information (such as online identifiers or browsing activity) available to our partners may be considered a “sale” under certain privacy laws.

We may collect, report and share personal information on an aggregated basis with technical service providers, such as web developers. For example, we may inform our service providers regarding the number of unique users of the Platform and aggregate information on the types of activities users conduct while using the Platform. We do not authorize such third parties to use your personal information except as necessary to provide services to us or for purposes authorized by us.

• Additionally, we may disclose your personal information (1) to comply with a law, regulation, or other governmental request, for example, to comply with subpoenas, court orders, legal process, or requests by law enforcement or governmental entities; (2) to investigate or defend against third-party claims against us; (3) to detect, prevent, or investigate fraud or other illegal activity or to enforce our Terms^[c] . (4) to repair or resolve technical issues in the operation of this Website; (5) to respond to a request by you or your authorized agent to disclose the information, including your requests to allow access to your account and personal information by third-parties designated by you; (6) with your knowledge and consent; and (7) to address emergencies or acts of god. Additionally, your personal information may be an asset transferred in the event of a merger other organizational combination or transfer involving Shacknews.

Lawful Bases for Collection and Use

Certain laws require us, or third-parties processing information on our behalf, to have one or more lawful grounds to collect and use the personal information that we have outlined above. We consider the grounds listed below to be relevant:

• Legal obligation. Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject.
• Contractual relationship . Where it is necessary for us to use your personal information in order to perform a contract to which you are a party (or to take steps at your request prior to entering a contract). An example would be requesting and using your payment card information in order to process a Mercury subscription you have purchased.
• Legitimate interests . We rely on this basis where applicable law allows us to collect and use personal information for our legitimate interests and the use of your personal information is fair, balanced and does not unduly impact your rights. For instance, it is in our legitimate interest to use personal information to protect the Platform from any attacks and to ensure appropriate security. When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
• Consent . We may obtain your consent to use your personal information in certain circumstances. We will ensure that when we use personal information based on consent that you are free both to give it and to decline to give it. Additionally, you may always withdraw your consent at any time without any further detriment to you.

Your Privacy Choices

There are various ways you can choose to access, update, or limit the personal information you provide to us and that we collect and process.

Account Preferences. If you have an account on our Platform you can update and make various changes to control the personal information that you share and we collect, including,

• From the Account settings tab you can change your email address or email settings, set comment filtering options, add or remove linked social media accounts, and change your account password. If you have a Mercury subscription you may also cancel it from the account settings page. You may also delete your account entirely as described in more detail below.
• From the Reader tab you can add or delete your favorite Feeds.

• From the Cortex control tab you can change the topics and other users you follow, create new posts and delete posts that you have previously authored.

Exercise Your Privacy Rights . All users of the Platform have the same basic privacy rights. While we strive to make it easy to exercise these rights directly from the Platform, if you ever have questions you may contact us at administrator@shacknews.com.  

• Information Access and Portability . You have the right to ask us what personal information we have about you. The easiest way for you to do this is to login to your Account. Once logged in you can see your activity. For example, if you want to see every comment you have ever made on the Chatty go to the Account settings tab and click on the My Chatty subtab. Similarly, if you want to see your Cortex posts, visit the Cortex tab. If there is something you have a question about that you cannot find on your own you can contact us and, subject to verification of your identity, we will do our best to help you find it.  

• Correction/Rectification . While you have the ability to edit most of your account information directly, for example the email we have on file for you, as described below, you also have the right to request that we correct any mistakes or inaccuracies in your personal information provided we are able to verify your identity.

• Deletion/Erasure . You are entitled to delete your personal information from the Platform to the fullest extent possible. To do this go to your Account page and click the Delete Account subtab and follow the instructions listed there. Please note that certain information may be excepted from your deletion request. For example, we may keep your information where necessary to detect and resolve issues related to system security and fraud detection. If after deleting your account you are not satisfied that your personal information has been removed from the Platform, you may contact us and we will do our best to assist you with your questions. You may also ask to have a post removed (or “nuked”) on the Chatty. This removes the post’s visibility on the Chatty for all users except for mods. Note that we cannot delete Chatty comments entirely without deleting all posts related to that post. We reserve the right, however, to edit posts or delete conversations that violate our Shack Community Guidelines .

• Objection . You have the right to object to our use of your personal information where our processing is based on legitimate interests (as described above) or is for direct marketing purposes.

• Restriction. In certain circumstances, you have the right to request that we restrict the processing of your personal information.

• Withdraw Consent . While we try not to rely on consent as a basis for processing your personal information, where we do rely on that basis you have the right to withdraw your consent at any time.

To exercise your rights you may contact us by email at administrator@shacknews.com  or as described below. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

If you are European resident, you also have the right to lodge a complaint with your local data protection authority about our collection and use of your personal information. We encourage you to contact us first so that we have an opportunity address your concern. You may reach us using the contact information below.

We will not discriminate against you for exercising any of the rights listed in this section. Specifically, we will not (1) deny you services or (2) provide you a different level or quality of services from other users of the Platform, except to the extent that not having your personal information limits our ability to provide you with desired services.  

Mobile Application Users. You may choose to uninstall our applications from your mobile device regardless of whether you are an account holder or not.

Unsubscribe from Emails . You may opt-out of receiving emails from us by following the “unsubscribe” instructions included in certain emails we send you or by sending an email to  administrator@shacknews.com . Note that even if you opt-out, you will still receive forgotten password recovery emails and other similar emails related to account maintenance when you request those from us.

Limit Public Posting . Any information that is disclosed in a Chatty comment or Cortex post will be available for viewing by other users. You should exercise caution when deciding to disclose personal information in these ways. Shacknews is not responsible for the disclosure of any information to any authorized user of the Platform and may not be able to remove such information once posted.

Google Analytics . As noted above, we use the Google Analytics service to gather and provide us with statistical data about how our Website is used. This Google service uses a cookie that can be recognized by Google when you visit other websites. You can opt out of Google Analytics’ collection and use of data generated by your use of the Website by going to  http://tools.google.com/dlpage/gaoptout .

Security of Personal Information

We take the security of personal information seriously. Our Platform has reasonable technical, physical and administrative security measures in place to protect the loss, misuse, unauthorized access, alteration and destruction of the personal information collected through the Platform. Reasonable efforts are made to secure our web servers, networks, host operating systems and databases against unauthorized access. Please remember that the security measures taken above are not foolproof; no website can guarantee that personal information will be protected in all situations. We cannot and do not guarantee that your personal information will never be accessed by an unauthorized party or otherwise breached. If we learn of a breach, we will comply with applicable law; however, unless a statute provides you have a right that cannot be waived, you specifically waive and covenant not to sue us for any data loss or breach of our system resulting in loss of personal information. See our Terms^[d] for more information.

Retention of Personal Information

We will retain your personal information for as long as we deem reasonably necessary or desirable, unless a different retention period is required by any applicable law, rule, or regulation. We reserve the right to delete or destroy any information collected, including personal information, at any time.

Other Important Information

Children . The services provided via the Platform are not directed at or intended for use by children under 16 years old. We do not knowingly collect or retain personal information from children under 16 through the Platform. If you are under the age of 16 you should not be visiting the Platform without parental consent. If you are under the age of 16 and are visiting or otherwise using the Platform without your parent’s knowledge and consent please discontinue such use immediately and do not disclose or provide any personally information to us. If you are a parent who learns that your child has provided us with personal information without your consent, please email us at administrator@shacknews.com  with sufficient detail to enable us to delete that information from our records. We will act promptly on your request to delete such information.

Cross-Border Information Transfers . If you are a resident of a country other than the United States, please be advised that we may transfer the personal information we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country for the purposes set out in this Policy. Your consent to this Policy followed by your submission of such information represents your agreement to that transfer, to the fullest extent allowed under the law. In all such instances where your personal information is transferred to the United States, we will take all reasonable steps necessary to ensure that appropriate safeguards designed to protect your personal information are implemented (e.g. entering into approved standard contractual clauses to protect personal information).

Third-Party Websites . Our Platform may contain links to other websites and other websites may reference or link to our Platform. We cannot control nor are we responsible for the privacy practices or the content of other websites. It is always a good idea to read the privacy policy on any third party website that you visit. We encourage you to be aware when you are leaving our Platform. This Policy applies only to personal information collected from our Platform.

Do Not Track Signals . Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

How to Contact Us

If you have questions about this Policy, or if you wish to correct, update, amend or delete/remove personal information that you have provided to us, you may contact us by email at  administrator@shacknews.com.

You may also write to us at:

Shacknews Ltd.

7257 Fulton Dr. NW

Suite #59-102

Canton, OH 44718

Updates to this Privacy Policy

We may update or change our privacy practices and this Policy from time to time. The date at the top of this Policy reflects the date of the most recent update. We will post a notice on the Platform to advise you of any significant changes to this Policy. Your continued use of the Platform signifies your continued assent to the terms of this Policy, as updated or amended at that time.