At Pandesa Corporation, doing business as ShareVault ("ShareVault"), we strive to protect the privacy of your information. This privacy statement covers the information management practices of ShareVault controlled public web sites or permission-based services that link to this privacy statement. These include the following websites:
ShareVault provides a link to this privacy statement on all pages requesting or controlling personal information
Information: What We Collect and How It Is Used
When a web site visitor or customer expresses interest in obtaining additional information about ShareVault's services or registers to use a ShareVault service, ShareVault may require the party to provide contact information, such as name, company name, address, phone number, and email address. When a party purchases a ShareVault service, ShareVault may require billing information, such as organization billing name, billing address, phone number, and credit card number. When a party utilizes a service or requests customer support for a service, ShareVault may request information such as name, company name, email address, and phone number. With the exception of credit card information, the information provided is generally stored electronically in secure ShareVault databases.
ShareVault's permission-based services are designed to facilitate repeat use by participants involved in multiple business transactions relying upon the services. Key to the security of these services and the business data contained therein, veriﬁcation of user’s virtual identity is fundamental to using this service. Participants must provide proﬁle information (name, title, company name, email address, and phone number) in order to utilize and secure the services.
In addition to the proﬁle information collected as described above, ShareVault also collects anonymous information about the use of our public web site, including but not limited to a visitor's IP address, the websites from which visitors access the ShareVault web site, the type of web browsers used to access the website, the time of the visit, and the pages viewed. This collected information does not personally identify individuals and is required to operate the service, for security, to fulﬁll certain legal requirements and statistical analysis of web site visits.
In order to collect the anonymous data described above, or to provide a better user experience for repeat users of our permission-based services, we may use "cookies" that remain in the cookies ﬁle of your browser at your option. Cookies are a widely utilized mechanism for storing small pieces of text which modern browsers use to interact with web sites. Your IP address will not be linked to any personal information unless you provide that information through any form on the website.
ShareVault Services Usage
In the provision of our permission-based services, ShareVault will maintain a history of participant access to the services and actions taken therein and make this available to the owner of a respective vault accordingly as part of our detailed user activity reporting / sharing analytics capabilities. ShareVault also may maintain a log of IP addresses from which users access the services to help secure our users.
Use of Personal Information
ShareVault uses the above collected information to inform our product customers and prospective customers about our solutions, to provide services requested by our customers, and to support our customers as they utilize our services. For example, ShareVault may respond to you, if you ﬁll out a "Contact" form on our website, with information about our services. ShareVault may also use data about ShareVault customers for its own marketing purposes, in order to provide information about product upgrades, user best practices, industry news, promotions or events. ShareVault uses credit card information solely to evaluate the ﬁnancial qualiﬁcation of prospective customers and to collect payment for services. ShareVault uses web site navigational information to operate and secure our web sites and to provide personalized information about the company.
ShareVault will not share, sell or distribute your personal data to unrelated third parties. All personal data may be disclosed only to third parties who directly support the use cases for personal data as summarized above. Owners of respective vaults are responsible for maintaining the access controls over their data and have access to personal user information and user activity related to their vault. This information is required to access and use the ShareVault services but is administered by the owner of each respective vault.
Various data related to the use of the service is retained indeﬁnitely by ShareVault for the duration of each respective service contract. The ShareVault owner may have made copies of access data as part of their own respective management practices and are outside the purview of this policy. Additional information related to ﬁnancial transactions is retained for a period of seven years.
Commitment to Data Security
Correcting and Updating Your Information
Users of ShareVault permission-based services may update or change their proﬁle information by logging into the service, selecting the "Preferences: Proﬁle" page, and updating information using the online interface. Organizations seeking to update information, to discontinue their ShareVault account, to have their private information returned to them please email, have questions, or need help should contact ShareVault by sending an email to firstname.lastname@example.org, or calling (408) 717-4955, ext. 2. Should you decline to receive mail or email from ShareVault that does not relate directly to your access to or use of ShareVault permission-based services, please visit our unsubscribe page and ﬁll out the form.
By using our websites and/or services, you signify your agreement to the privacy polices described above. If you have any questions about this privacy statement, please email us at email@example.com.
For California Residents
California residents can request and obtain from us once a year a list of all third parties to which ShareVault has disclosed certain information during the preceding calendar year for the third parties' direct marketing purposes. If you are a California resident and want such a list, please contact us by email to firstname.lastname@example.org.
Notice to Users Outside the U.S.
EU-U.S. and Swiss-U.S. Privacy Shield
ShareVault is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and assumes liability for protection of your personal information in cases of onward transfers to third parties.
In compliance with the Privacy Shield Principles, ShareVault commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact ShareVault at https://www.privacyshield.gov/.
ShareVault has further committed to refer unresolved Privacy Shield complaints to the United States Council for International Business. Alternatively, you may use JAMS. JAMS is the independent organization also responsible for reviewing and resolving complaints about our Privacy Shield compliance. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact JAMS at https://www.jamsadr.com/eu-us-privacy-shield or United States Council for International Business at https://www.uscib.org/privacy-shield/. The services of JAMS are provided at no cost to you or you can visit https://www.privacyshield.gov/ for more information or to file a complaint.
GENERAL DATA PROTECTION REGULATION (GDPR)
As a citizen or resident of the EU, your personal data are protected by the terms of the GDPR. In order for ShareVault and ShareVault's customers to comply with the GDPR, you are required to grant consent in order to gain access to ShareVault and to exercise additional privacy rights. Most provisions extended under the GDPR are described in the statements above with additional options and features described below.
GDPR Data Rights
The GDPR provides the following data rights for individual citizens or residents of the EU:
1. The Right to Be Informed
Should there be a breach of private information, you will be notiﬁed using the contact information in your user proﬁle. We will also notify the appropriate privacy authority for your home country.
2. The Right of Access
In addition to accessing user proﬁle information (see above), your use events may be obtained by contacting the owner of the respective vaults you have access to. Detailed records of technical mechanisms related to enabling those access events are not generally accessible.
3. The Right to Rectification
Users may access and update personal information as detailed above under Correcting and Updating Your Information.
4. The Right to Erasure
Users may at any time chose to remove themselves from the ShareVault service. Users should ﬁrst contact the ShareVault owner / administrator in order to exercise the right to erasure. In the event that the ShareVault owner / administrator cannot be reached, users can send an email to email@example.com
5. The Right to Restrict Processing
6. The Right to Data Portability
7. The Right to Object
Users may object to the collection and use of personal information by ﬁrst contacting the ShareVault owner / administrator. In the event that the ShareVault owner / administrator cannot be reached, users can send an email to firstname.lastname@example.org.
8. Rights in Relation to Automated Decision Making and Proﬁling
Automated decision making and profiling is not applicable to the use of ShareVault Services.
9. Right to Independent Resolution
Users whose objections are not resolved by ShareVault and who are eligible may contact the United States Council for International Business as provided under the terms of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (Privacy Shield), where ShareVault is listed as a verified compliant company.
10. Right to Independent Arbitration
Users whose objections are not resolved by any other means, may contact the International Centre For Dispute Resolution to invoke binding arbitration to determine whether ShareVault has violated its obligations to an individual and whether any such violation remains fully or partially un-remedied.
Users may exercise rights related to the collection and use of personal information per the statements above or by email at email@example.com.
Changing / Withdrawing Consent
After granting consent, users can subsequently change / withdraw their consent to the collection, use and storage of personal information by emailing firstname.lastname@example.org.
Legal basis for the collection and use of personal information is detailed in the above statements and generally starts with explicit consent by a user, followed by additional requirements to support the terms of the ShareVault service contracts, support the secure function of the ShareVault service, and as required for legal reasons, speciﬁcally to comply with the requirements of the GDPR and various US legal statutes.
ShareVault provides services to customers who use these services to in turn support their own individual business functions. These ShareVault owners / administrators create users for these services are considered data controllers for certain types of user data related to their respective vaults. ShareVault is thus the processor for that data. ShareVault customers (owners / administrators) share the responsibility for this category of data and are provided the tools to fulﬁll that obligation for their users who are eligible for the additional GDPR privacy rights.
ShareVault customers share personal information with ShareVault to establish and maintain services, and for this information ShareVault is the Controller and is bound contractually as part of the contract for services.
Aﬃliated third party providers who in turn support the ShareVault service also share responsibility as Processors and Sub-Processors in a similar manner.
All parties with support roles or access to applicable personal information within ShareVault, are appropriately bound by contract to be compliant with the GDPR principles.
Help for Admins / Owners with GDPR Compliance
GDPR compliance is a shared responsibility between ShareVault customers (owners / administrators) and ShareVault. Owners / administrators can request help from ShareVault for complying with GDPR compliance, including support for users who wish to exercise any of their rights under the GDPR, by sending an email to email@example.com.
Changes to This Privacy Statement
All personal information (deﬁned as any information that identiﬁes or can be used to identify the person to whom such information pertains) that we collect and maintain will be subject to this privacy statement, as amended from time to time. ShareVault may change this privacy statement from time to time at its sole discretion and will provide notice of all changes in this online document and via the footer of the web pages with authorized links to this document. If as the result of such changes you want to alter the ways in which ShareVault is allowed to use your personal information, you can do so by following the procedure described under Correcting and updating your information, above.