Last Updated: December 13, 2021

 

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Shield Financial Compliance Ltd (together, “Shield FC” “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:

  • When you browse or visit our website, https://www.shieldfc.com/ (“Website”);
  • When you make use of, or interact with, our Website
    1. When you request to schedule a demo
    2. When you contact us
  1. When we process your job application
  • When you make use of, or interact with, our platform (“Platform”).
    1. When you create an account and when you log in
  • When you attend a marketing event and provide us with your personal data
  • When you exchange business cards with us
  • When we use the personal data of our customers (e.g. contact details)
  • When we use the personal data of our resellers, distributors, agents and/or finders (e.g. contact details)
  • When we use the personal data of our service providers (e.g. contact details)
  • When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

 

Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal data” or “personal information” means any information that can be used, alone or in combination with other data, to uniquely identify an individual. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions.

 

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

 

Table of contents:

  1. What information we collect, why we collect it, and how it is used
  2. How we protect and retain your personal data
  3. How we share your personal data
  4. Additional information regarding transfers of personal data
  5. Your privacy rights
  6. Use by children
  7. Interaction with third-party products
  8. Log files
  9. Analytic tools
  10. Specific provisions applicable under California privacy law
  11. How to contact us

 

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement significant changes to the use of your personal data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

 

 

  1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
Specific personal data we collect

 

Why is the personal data collected and for what purposes?Legal basis (GDPR only, if applicable)Third parties with whom we share your personal dataRetention period

 

Consequences of not providing personal data
When you browse or visit our Website
Data on how the Website is accessed and used (“Usage Data”) in particular:

·       IP address

·       browser type

·       browser version

·       the pages of the Website that you visit, the time and date of your visit, the time spent on those pages

·       unique device identifiers

·       other diagnostic data

·       Cookies, analytic tools and log files

For more information, please read our cookies policy below

We may use and store information about your location if you give us permission to do so (“Location Data”). You can enable or disable location services when you use our Service at any time by way of your device settings.

·       To gather analysis or valuable information so that we can improve our Website

·       To monitor the usage of our Website

·       To detect, prevent and address technical issues

·       To provide features of our Service, to improve and customize our Service

·       Consent

·       Legitimate interest (e.g., essential cookies)

3rd party platforms such as for the following purposes:

Google Analytics – website analytics

 Google AdWords -Marketing

 HubSpot email communications and CRM

 Facebook Advertising – Marketing

 LinkedIn Campaign Manager – Marketing

Twitter Advertising – Marketing

 

 

 

 

For more information, please read our cookies policy below

 

·       Cannot gather analysis or valuable information so that we can improve our Website

·       Cannot monitor the usage of our Website

·       Cannot detect, prevent and address technical issues

·       Certain Website features may not be available

Read more about the purposes of each cookie below

When you request a demo
·       First name

·       Last name

·       Email address

·       Company name

·       Job function

·       Country/ region

 

·       To be able to provide you with a demo of our platform

·       To communicate with you when coordinating and providing the demo

 

  • Legitimate interest (to provide you a demo)
  • Processing is necessary for the performance of a contract (i.e. license agreement) to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract
3rd party platforms such as for the following purposes:

 Google AdWords -Marketing

 HubSpot email communications and CRM

 Facebook Advertising – Marketing

 LinkedIn Campaign Manager – Marketing

Twitter Advertising – Marketing

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.
  • Cannot provide you a demo
  • Cannot communicate with you when coordinating and providing the demo
  • Full name
  • Email address
  • Company name
  • Job function
  • Country/ region

 

 

  • To send you marketing communications
  • Consent
  • Legitimate interest (e.g. marketing)

 

3rd party platforms such as for the following purposes:

Google AdWords -Marketing

 HubSpot email communications and CRM

 Facebook Advertising – Marketing

 LinkedIn Campaign Manager – Marketing Twitter Advertising – Marketing

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.
  • Cannot send you marketing communications

 

 

When you contact us by email
·       Full name

·       Email address

·       Any other information that you decide to provide/supply us

 

·       To receive, process and respond to your request
  • Legitimate interest (i.e. to respond to requests)
  • Processing is necessary for the performance of a contract (i.e. license agreement) to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract
3rd party platforms such as for the following purposes: Google AdWords -Marketing

 HubSpot email communications and CRM

 Facebook Advertising – Marketing

 LinkedIn Campaign Manager – Marketing

Twitter Advertising – Marketing

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.·       Cannot receive, process and respond to your request
·       Full name

·       Email address

 

·       To send you marketing communications·       Consent

·       Legitimate interest (e.g. marketing)

 

3rd party platforms such as for the following purposes: Google AdWords -Marketing

 HubSpot email communications and CRM

 Facebook Advertising – Marketing

 LinkedIn Campaign Manager – Marketing

Twitter Advertising – Marketing

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.·       Cannot send you marketing communications
When we process your job application
·       Full name

·       Email address

·       CV/cover letter

·       Any other information that you decide to provide/supply us

 

·       To assess you as a candidate

·       To analyze your application

 

Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract (i.e. employment contract).

Legitimate interest (e.g. to assess you as a candidate).

3rd party platforms such as for the following purposes:  HubSpot email communications and CRM

 

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

 

When you attend a marketing event and provide us with your personal data
·       Full name

·       Job title

·       Email address

·       Company name

·       Phone number

·       Any other information that you would provide us

 

·       To establish a business connection

·       To send you marketing communications

·       Consent

·       Legitimate interest (e.g., to establish a business connection)

3rd party platforms such as for the following purposes:

Google AdWords -Marketing

 HubSpot email communications and CRM

 Facebook Advertising – Marketing

 LinkedIn Campaign Manager – Marketing

Twitter Advertising – Marketing

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.·       Cannot establish a business connection

·       Cannot send you marketing communications

When you exchange business cards with us
·       Full name

·       Job title

·       Email address

·       Company name

·       Phone number

·       Any other information that you would provide us

 

·       To establish a business connection

·       To send you marketing communications

  • Consent
  • Legitimate interest (e.g., to establish a business connection)
3rd party platforms such as for the following purposes:

Google AdWords -Marketing

 HubSpot email communications and CRM

 Facebook Advertising – Marketing

 LinkedIn Campaign Manager – Marketing

 Twitter Advertising – Marketing

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.·       Cannot establish a business connection

·       Cannot send you marketing communications

When we use the personal data of our customers (e.g. contact details)
·       Full name

·       Email address

·       Phone number

·       Company name and details

·       Payment information

·       Any other information that you decide to provide/supply us

·       To provide our products and services

·       To perform the applicable agreement

·       To communicate with our customers/clients

·       Processing is necessary for the performance of a contract to which our customer is a party

·       Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.)

·       Legitimate interest (e.g. send you contract-related communications)

3rd party platforms such as for the following purposes:

Google AdWords -Marketing

 HubSpot email communications and CRM

 Facebook Advertising – Marketing

 LinkedIn Campaign Manager – Marketing

Twitter Advertising -Marketing

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

 

 

·       Cannot provide our products and services

·       Cannot perform the applicable agreement

·       Cannot communicate with our customers/clients

 

When we use the personal data of our service providers resellers, distributors, agents and/or finders (e.g. contact details) 
·       Full name

·       Email address

·       Phone number

·       Company name

·       Any other information that you decide to provide/supply us

·       To contact our service providers, resellers, distributors, agents and/or finders

·       To perform the applicable agreement

 

Processing is necessary for the performance of a contract (i.e. Services Agreement) to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g. perform the contract, send contract-related communications)

3rd party platforms such as for the following purposes:

Google AdWords -Marketing

 HubSpot email communications and CRM

 Facebook Advertising – Marketing

 LinkedIn Campaign Manager – Marketing

Twitter Advertising – Marketing

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

 

 

·       Cannot communicate with you

·       Cannot perform the applicable agreement

When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)
·       Full name

·       Email address

·       Social media channel

·       Any other data you decide to provide/supply

·       To respond to your requests in our social media channels·       Legitimate interest (e.g. respond to your requests in our social media channels)3rd party platforms such as for the following purposes:

 HubSpot email communications and CRM

 Facebook Advertising – Marketing

 LinkedIn Campaign Manager – Marketing

Twitter Advertising – Marketing

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.
  • Cannot respond to your request in our social media channels
·       Full name

·       Email address

·       To send you marketing communications·       Consent

·       Legitimate interest (e.g., marketing)

3rd party platforms such as for the following purposes:  

HubSpot email communications and CRM

 

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.·       Cannot send you marketing communications

 

Finally, please note that some of the abovementioned personal data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your personal data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

 

  1. HOW WE PROTECT AND RETAIN YOUR INFORMATION

 

  • Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

 

  • Retention of your personal data. In addition to the retention periods mentioned above, in some circumstances, we may store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings. We have an internal data retention policy to ensure that we do not retain your personal data perpetually. Regarding the retention of cookies, you can read more in our cookie policy below.

 

  1. HOW WE SHARE YOUR PERSONAL DATA

 

 In addition to the recipients described above, we may share your personal data as follows:

 

  • With our business partners, such as resellers, with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.
  • To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  • If in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events to the maximum extent permitted under applicable laws;
  • In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events to the maximum extent permitted under applicable laws; and/or
  • Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

 

  1. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

 

  • Storage: We store personal data on AWS’s servers in North Virginia – US – subject to standard contractual clauses included in our agreement with AWS.

 

  • Internal transfers: to the extent we will conduct transfers within the Shield FC group, we will, to the extent required under applicable data protection law, be covered by an internal processing agreement entered into by members of the Shield FC (an intra-group agreement) which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred to.

 

  • External transfers: Where we transfer your personal data outside of EU/EEA, we rely on i) Adequacy Decisions as adopted by the European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission.

 

 

  1. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

 

  • Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
  • You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however, we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
  • You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
  • You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims as mentioned in Section 3 above;
  • You have the right to object, to or to request restriction, of the processing;
  • You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format and that you have the right to transmit that data to another controller;
  • You have the right to object to profiling;
  • You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular, if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
  • You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

 

  • You can exercise your rights by contacting us at info@shieldfc.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

 

  • Deleting your account: Should you ever decide to delete your account, you may do so by emailing info@shieldfc.com. If you terminate your account, any association between your account and personal data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

                                                                          

  1. USE BY CHILDREN

 

We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without the involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at info@shieldfc.com.

 

  1. INTERACTION WITH THIRD PARTY PRODUCTS

 

We may enable you to interact with third-party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third-Party Service.

 

  1. LOG FILES

 

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

 

  1. ANALYTIC AND BEHAVIOURAL REMARKETING TOOLS

 

  • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about the use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with the personal information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

 

 

 

 

We reserve the right to remove or add new analytic tools.

 

  1. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

 

  • Our California Do Not Track Notice: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, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

 

  • Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or personal information you have publicly posted.  If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law.  Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

 

  • Your Choices.You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any issue to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

 

  1. CONTACT US

 

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at info@shieldfc.com.