Shoflo Privacy Policy

Effective Date: May 25th, 2018 

Last Updated: December 11, 2020

Shoflo, LLC. (“Shoflo,” “we,” “our” or “us”) knows that you care how information about you is used and shared. This Privacy Policy explains what personal information of yours will be collected by Shoflo when you access the Shoflo Services (including through the websites of our partners), how the information will be used, and how you can control the collection, correction and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms and Conditions (available at https://shoflo.tv/terms/).

References to information in this Privacy Policy refer to personal information, which is information that can be associated with a specific person and used to identify that person. Personal information does not include information that has been anonymized so that it does not identify a specific user, which may be used for any legal purpose.

Please read this policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this Privacy Policy.

 

Information We Collect

We obtain information about you from a variety of sources, including from you, your interaction with Shoflo, and third parties. Such information may include your name, postal address, e-mail address, and telephone number, among other personally identifiable information.

Our Services: We may collect personally identifiable information about you through our Services in connection with the creation and management of your account for Shoflo’ services and events, such as a name, email address, and a password to create a Shoflo account.

Additionally, if you use certain Services, you may be required to provide us certain information: (i) information that you provide by filling in forms on our website; (ii) information when you report a problem with our Services; (iii) records and copies of your correspondence, if you contact us; (iv) your responses to surveys that we might ask you to complete for research purposes; (v) details of transactions you carry out through our Services and of the fulfillment of your orders; and (vi) your search queries on our website or through our Services. The content which you upload, download, or view on our services may, but does not necessarily, contain Personal Information. When we refer to “Content” in this notice, we mean the Personal Information that we process at your direction. In legal terms, we act as data processors for the Personal Information included in the Content.

If you have purchased a paid version of the Shoflo’s services or events, we will collect information about the purchase or transaction.

We may collect your usage information about how you use the Services, including your access times, location, browser types and language, and Internet Protocol addresses. We may collect device-specific information when you access our Services, including your hardware model, operating system and version, unique device identifiers, mobile network information, and information about the device's interaction with our Services. If you choose to purchase a product from us, we or our third-party payment processors will collect your payment information also. We also collect data through our partners (customers) who use our Services (including by embedding our code on their websites) to analyze usage of their websites. When you use our Services or if you visit such websites, your browser may send us certain information about you as described below. 

 

Cookies Information: 

We may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets us learn about your behavior and usage patterns when you are on our Services. A cookie may also convey anonymous information about how you browse a partner website to us. A cookie does not collect personal information about you. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Services. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent.

 

Log File Information: 

Log file information is automatically reported by your browser each time you access a web page on our Services. When you access the Services, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.

 

Clear Gifs Information:

When you access the Services, we may employ clear gifs (also known as web beacons) which are used to track the online usage patterns of our users anonymously. No personally identifiable information from your Shoflo account is collected using these clear gifs. The information is used to enable more accurate reporting, improve the effectiveness of our Services, and make Shoflo better for our users and partners.

 

How We Use Your Information

We use the information that we collect to operate and maintain our Services; to deliver information and support your requests, including receipts, technical notices, security alerts, and support and administrative messages; and to help our partners improve their online offerings.

Additionally, we use information that we collect about you or that you provide to us, including any personal information:

  • To provide you with information, products or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account/subscription, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Services or any products or services we offer or provide though them.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use information about you (i) to track and analyze trends and usage in connection with our Services; (ii) to protect our rights or property; (iii) to compare information for accuracy; (iv) to verify your identity; (v) to investigate and prevent fraud or other illegal activities; and (vi) for any other purpose disclosed to you in connection with our Services.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences.

We use cookies, clear gifs, and log file information to: (a) monitor the effectiveness of our Services and the offerings of our partners; (b) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (c) diagnose or fix technology problems; (d) and allow our business partners to deliver advertisements to you as described below.

 

Our Legal Basis for Collecting Personal Information

Whenever we collect Personal Information from you, we may do so on the following legal bases:

  1. Your consent to such collection and use;
  2. Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
  3. Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Information is necessary for:
    • Intra-organization transfers for administrative purposes;
    • Product development and enhancement, where the processing enables Shoflo to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our Users, and to better understand how people interact with our Sites;
    • Fraud detection and prevention;
    • Enhancement of our cybersecurity, including improving the security of our network and information systems; and
    • General business operations and diligence;

Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes. 

 

How We Share Your Information

 

Personally Identifiable Information: 

Shoflo will not rent or sell your personally identifiable information to others. We may store personal information in locations outside the direct control of Shoflo (for instance, on servers or databases co-located with hosting providers). Any personally identifiable information you elect to make publicly available on the Services will be available to other users. If you remove information that you have made public on the Services, copies may remain viewable in cached and archived pages of the Services, or if other users have copied or saved that information.

 

Instances where we are required to share your information:

Shoflo will disclose your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms and Conditions or to protect the security or integrity of our Services; and/or (c) to exercise or protect the rights, property, or personal safety of Shoflo, our users or others.

What happens in the event of a change of control: We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses, and other user information related to the Services may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company.

 

Your Privacy Rights and Choices

You may have certain rights relating to your Personal Information, subject to local data protection law. We aim to provide you with choices about how we use your Personal Information. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.

Shoflo understands the importance of privacy and is committed to collecting and handling Personal Information in accordance with all applicable privacy laws including the Australian Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”).

 

Privacy Rights Specific to European Union Residents

The European Union’s General Data Protection Regulation (“GDPR”), and corresponding legislation in the United Kingdom and Switzerland, provide European, Switzerland and United Kingdom residents with certain rights in connection with Personal Data you have shared with us. If you are resident in the European Economic Area, you may have the following rights:

  • The right to be informed. You are entitled to be informed of the use of your Personal Data.  This Privacy Policy provides such information to you.
  • The right of access. You have the right to request a copy of your Personal Data which we hold about you.
  • The right of correction. You have the right to request correction or changes of your Personal Data if it is found to be inaccurate or out of date. 
  • The right to withdraw consent. You have the right to withdraw a previously given consent for processing your Personal Data for a specific purpose.
  • The right to be forgotten. You have the right to request us, at any time, to delete your Personal Data from our servers and to erase your Personal Data when it is no longer necessary for us to retain such data.  Note, however, that deletion of your Personal Data will likely impact your ability to use our services.
  • The right to object (opt-out). You have the right to opt-out of certain uses of your Personal Data, such as direct marketing, at any time. 
  • The right to data portability. You have the right to a “portable” copy of your Personal Data that you have submitted to us.  Generally, this means your right to request that we move, copy or transmit your Personal Data stored on our servers or information technology environment to another service provider’s servers or information technology environment.
  • The right to refuse to be subjected to automated decision making, including profiling. You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
  • The right to lodge a complaint with a supervisory authority. You have the right to lodge complaints about our data processing activities by filing a complaint with us or with the relevant Supervisory Authority. A list of Supervisory Authorities is available here:  http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

You may exercise any of the rights described in this section by sending an email to via email to privacy@shoflo.tv. All customers or their legal representatives may update or correct information about yourself by making changes to your profile or submitting a request via email to privacy@shoflo.tv. Please note that we may ask you to verify your identity and request before taking further action on your request. We may respond to your request by letter, email, telephone or any other suitable method. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.

 

Rights Specific to Hong Kong Residents

Shoflo is required to comply with the Hong Kong law in respect of its operations there. Shoflo seeks to comply with the requirements of Hong Kong’s Personal Data (Privacy) Ordinance (“PDPO”).

Shoflo’s Privacy Policy shall apply to its operations in Hong Kong, and this section should be read along with the Privacy Policy, “Information We Collect” and “How We Use Personal Information.”

 

Use of Personal Data for Direct Marketing in Hong Kong

As in other jurisdictions, Shoflo intends to use Personal Data collected from Hong Kong residents to send them marketing communications offering or advertising the availability of our Services (“Direct Marketing”). Under the PDPO, we may not use such Personal Data for Direct Marketing unless we have received consent from these individuals for that intended use.

  1. Types of Personal Data

We may use your name, email address, mailing address and phone number and information about your preferences for Direct Marketing. These preferences may relate to both the business lines which you prefer for receiving Direct Marketing from us and the types of Services in which you are interested.

  1. Classes of Marketing Subjects

Your Personal Data may be used for Direct Marketing in relation to the following:

  • News and information;
  • Services offered by Shoflo.
  1. Communication of Your Consent

You may communicate your consent to our use of your Personal Data for Direct Marketing when:

  • Providing us with your Personal Data through our website, clicking on the button indicating your consent;
  • Providing us with your Personal Data through a form, signing the form to indicate your consent;
  • Following the instructions in the document on which you are providing your Personal Data to us.

If you do not agree to the use of your Personal Data for Direct Marketing, you may opt-out from receiving marketing communications from us at any time by following the opt-out instructions found in in this Privacy Policy. 

 

Your Rights and Choices Under PDPO

The PDPO provides Hong Kong residents with specific rights regarding their Personal Data. This section describes PDPO rights and explains how to exercise those rights if they apply to you.

  1. Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection and use of your Personal Data.  We have 40 days to produce this information. The response we provide will also explain the reasons we cannot comply with a request, if applicable.  
  2. The right to rectification: If the individual discovers that the information we hold on them is inaccurate or incomplete, they can request that it be updated. As with the right to access, we have 40 days to do this, and the same exceptions apply.

 

Exercising PDPO Rights

To exercise your rights, please submit your request to privacy@shoflo.tv or by using the contact information provided above and we will consider your request in accordance with applicable law. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file.  If we no longer need to process Personal Data about you in order to provide our Services or our Site, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

We endeavor to respond to a verifiable consumer request within forty (40) days of its receipt consistent with applicable law.

We may charge a reasonable administrative fee to process or respond to your verifiable consumer request. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Rights Specific to Brazilian Residents

The Lei Geral de Proteção de Dados (LGPD) is a new Brazilian privacy law that came into effect on September 18, 2020. A Brazilian Data Protection Authority ("DPA") will be established and will provide guidelines on how to interpret and implement the LGPD’s requirements. As those guidelines are not yet established, our approach is subject to change.

If you are habitually located in Brazil, you have rights under LGPD, including the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. You can find more information about how to exercise these rights in the section above entitled “Rights Specific to European Union Residents.”

If you have questions about your rights, you may contact us at privacy@shoflo.tv.

The LGPD requires us to have legal bases to collect, use, share and otherwise process information about you. You can find a description of the legal bases we rely on by reviewing the above section entitled  “Our Legal Basis for Collecting Personal Information.”

 

Ads

We, along with third-party business partners, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) to allow our third-party business partners, including Google, ad servers, and ad networks, to serve you advertisements (“ads”) based on your prior visits to our Services. These ads are delivered to you on third-party websites and services across the Internet. These third-party business partners use technology to send, directly to your browser or mobile device, the ads and ad links that appear on third-party sites, and will automatically receive your IP address when they do so. Along with cookies, they may also use other technologies (such as JavaScript, device identifiers, location data, and clear gifs, see above) to compile information about your browser’s or device’s visits and usage patterns on the Services, and to measure the effectiveness of their ads and to optimize and personalize the advertising content. Shoflo does not sell, rent, or share the information we collect directly from you or about you from third parties with these third-party business partners for such parties’ own marketing purposes.

Other: Additionally, we may share personal information about you as follows:

  • To our subsidiaries and affiliates.
  • To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To fulfill the purpose for which you provide it.
  • With your consent or direction.

We may also share non-personally identifiable information (aggregated or otherwise) with third parties for any reason.

 

Direct Marketing and “Do Not Track” Signals

Shoflo does not track its users over time and across third-party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.

California residents are entitled to contact us to request information about whether we have disclosed Personal Information to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes. To make such a request you should send (a) an email to privacy@shoflo.tv with the subject heading “California Shine the Light Privacy Rights,” or (b) a letter addressed to Shoflo, LLC, Attention: Privacy, 1 South Orange Avenue #300, Orlando FL 32801.  In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response.  We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

 

Email and other communications

You may opt out of receiving email and other communications from us at any time by using one of the following methods: (1) select the email “opt out” or “unsubscribe” link, or follow the opt-out instructions included in each email communication; or (2) contact us using the details set out in this privacy notice. When contacting us, please ensure that you provide us with sufficient information to deal with your request, including your first and last name, email and/or postal address (as applicable), and specific information about the communications that you no longer wish to receive. All unsubscribe requests will be managed within ten days of receipt. Employees will not send any further communication by electronic means to the unsubscribed party.

It is Shoflo’s policy that all its communications with third parties comply with the requirements of Canada’s privacy legislation, the Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Canada’s Anti-Spam Legislation, (“CASL”), and our own commitment to protecting our clients’ privacy.

 

Storage and Processing

Your information collected through the Services may be stored and processed in the United States or any other country in which Shoflo or its subsidiaries, affiliates or service providers maintain facilities. Shoflo may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which Shoflo or its parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy. We will take all steps necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. We have put in place commercially reasonable technical and organizational procedures to safeguard the information and Personal Information we collect on the Sites.

 

Our Retention of Your Personal Information

We use and retain your Personal Information for as long as necessary to fulfill the purpose for which it is being processed, to carry out legitimate business interests, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your Personal Information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.

 

How We Protect Your Information

Shoflo is concerned with protecting your privacy and data. When you enter sensitive information (such as credit card number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). Unfortunately, the transmission of information via the Internet is not completely secure, and we cannot ensure or warrant the security of any information you transmit to Shoflo or guarantee that your information on the Services may not be accessed, disclosed, altered, or destroyed by breach of any of our industry standard physical, technical, or managerial safeguards. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on or within the Services.

We use an outside help platform and a credit card processing company to bill you if you purchase services. These companies are not authorized to retain, share, store or use personally identifiable information for any other purposes.

Your Choices About Your Information

You can review and correct the information about you that Shoflo keeps on file by logging into your account to update your password and billing information. Alternatively, you can contact us directly at privacy@shoflo.tv or support@shoflo.tv.

 

Children’s Privacy

Protecting the privacy of young children is especially important. For that reason, Shoflo does not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 is allowed to access or use the Services or to provide any personal information to Shoflo. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at support@shoflo.tv.

 

Notification Procedures

It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email notice, written or hard copy notice, or through conspicuous posting of such notice on the Services, as determined by Shoflo in its sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.

 

Links to Other Web Sites

We are not responsible for the practices employed by websites or services linked to or from the Services, including the information or content contained therein. Please remember that when you use a link to go from the Services to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies.

Additionally, some content or applications, including advertisements, on or through the Services are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

 

Third-Party Ad Servers and Networks

The Shoflo Privacy Policy does not apply to, and we cannot control the activities of, third-party ad servers and ad networks. Please contact or consult the respective privacy policies of such ad servers or ad networks for more information.

 

Changes to Our Privacy Policy

If we change our privacy policies and procedures materially, we will post those changes on the Services to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page. When we change the policy in a material manner we will let you know and update the ‘effective date’ at the top of this page.

 

How to Contact Us

If you have any questions, comments or concerns about this Privacy Policy, or if you would like to exercise the choices discussed above, please contact us:

Via e-mail: privacy@shoflo.tv

By writing to us:

Shoflo, LLC

Attn: Privacy Policy Inquiry

1 South Orange Avenue #300

Orlando, FL 32801