Privacy policy

Effective: 17 October, 2022 ("Effective Date")

Introduction

This privacy policy ("Privacy Policy") is intended to inform you about Share Panel's ("Share Panel", "we", "us", or "our") policies and procedures for the collection, use and disclosure of your information in connection with your use of Share Panel's service. Share Panel provide an internet-based service ("Service") created to help users with Share Panel accounts ("Users") to share their information, content and files ("Materials") and analyze if and how their Materials are viewed and engaged with by Materials recipients ("End-Users"). Users access our Service at the website address https://app.sharepanel.co (the "Site"). A "Device" is any computer used to access the Share Panel Service, including but not limited to a desktop, laptop, smart phone, tablet, or any other consumer electronic device.

When you interact with the Site of the Service or with our events, sales and marketing activities we collect information that, in isolation or in combination with other information can be used to personally identify you ("Personal Data").

Scope

This Privacy Policy applies to your access of our Service, however accessed, and sets out what data we collect when you use the Site or the Service. We will also describe why we collect this data, what we use it for, and your choices and rights. This policy is applicable to personal data and any other information collected by us from or in regards to: (i) visitors to, or users of, our Site and Service, (ii) prospective clients, (iii) current clients.

We collect information on End-Users on behalf of our Users as part of providing our Service. Our use of this information is defined by the contract between the specific User and us. We are not responsible for the privacy practices or policies of our Users.

By using our Service or Site, you consent to our collecting, transferring, processing, storing your data as described in this policy.

1) What information do we collect?

1.i) As a User of the Service

When you register to become a User of our Service you will need to provide Personal Data including but not limited to your full name, email address, telephone number, home or business address. You may also choose to submit Personal Data to us via email or use other interactive features offered as part of the Service.

If you opt for our one of our paid Service levels then you may be asked to submit more Personal Data including but not limited to your credit or debit card information.

When using the Service you may also submit your End-Users' full names and email addresses when sharing Materials with them via a web link.

1.ii) Information Share Panel receives from End-Users

As an End-User, if the User sending you Materials has requested it you may need to provide your email address to access the Materials sent. We will store your email address on behalf of the User that sent the Materials. As an End-User if you want your email address to be removed from Share Panel's databases please request this from the User who sent you the Materials. Stored email addresses may be subject to the User's privacy policies and practices as well as those detailed in this Privacy Policy.

• If you are an End-User accessing Materials sent by a User we collect information about your engagement and interactions with the Materials sent. This data includes:
• If you opened the unique link that contains the Materials sent
• Time and date of when you opened the Materials link
• Which individual items within the collection of Materials you viewed
• Time and date of when you opened an individual Materials item
• How long you viewed a specific Materials item (e.g. .pdf file)
• Whether you used the "Download" button on a specific Materials item

1.iii) Cookies

Share Panel uses "cookies" (small data files that are transferred on to your device) to run and administer the Site and the Service, deliver adverts, monitor trends, and improve your access and use of our Service. Our full Cookie Policy can be found here: https://sharepanel.co/cookies.

2) How we use your Personal Data

2.i) Provide our Service to Users

As an active User of our Service we store and use your Personal Data in relation to sign-up, purchases, use and support with your account. We may also use this data to contact you with important updates about your account, including but not limited to changes to the Service or Site. This is necessary for delivering obligations relating to the contract between the User and the Service, and is inclusive of EU data subjects.

When End-Users interact with your content we collect Personal Data on your End-User's behavior on your behalf so that we can give you as a User in accordance with the appropriate User contract. Share Panel does not access, modify or use your End-Users' Personal Data unless required to provide our Service (for example to provide assistance with a problem) expressly and exclusively at the Users' request.

2.ii) Responding to requests and supplying information

If you actively request information about the Service, for example requesting an example Materials link email from the Site, or registering for a webinar, we will use your Personal Data to to respond to your request, for example using your email address This is inclusive of EU data subjects as it is necessary to respond to or action your request.

2.iii) For Legitimate Business Interests

We may use data that relates to your interaction and use of the Site and the Service, for example data received via cookies, for specific legitimate business interests or to deliver the obligations of our contract with you. These interests include:

• to deliver, support and administer the Site and the Service
• to improve and/or personalize your access to and use of the Site and the Service
• to customize our marketing approaches and personalize our communications with you (for example informing you of useful features that may be relevant to how you use the Site or the Service)
• to inform internal research and development
• to verify User authorization and security
• to provide analytical insights
• to monitor performance and content use
• to administer data in accordance with our internal processes including auditing, quality control, repairing data, preventing fraud or other illegal activity, misuse of the Service or the Site, supporting prosecutions, and maintaining the security of any IT systems relating to the Site or the Service.
• (bare minimum details) to prevent you from being subject to further marketing communications or data processing where you have requested us to delete or modify your data

Where such laws apply (for example as a data subject in the EU) this use of your data is necessary for the legitimate interests we have in understanding how the Site and the Service are used by you and to improve yours and others experience. Similarly, Cookies, with your permission, are also placed on your device for the reason of legitimate interests.

2.iv) Communicating Marketing or other announcements with our Users

We may use your Personal Data (including but not limited to your email address, personal or business mailing address or telephone number) to contact you with information about our products and services, events and other promotions. We always provide an unsubscribe functionality on all applicable channels. If you unsubscribe from our general communications we will still contact you for important account issues, for example if your billing method is not working.

Where such laws apply (for example as a data subject in the EU) we will only send you marketing information to your email address, personal or business mailing address or telephone number if you consented for us to do this when you originally provided your Personal Data. You have the right to withdraw this consent at any time and the means to do so will be included as an "opt-out" functionality in any such communication.If you would like to manually initiate this process at any time you can do so by emailing us at hello@sharepanel.co.If you "opt-out" from our general communications we will still contact you for important account issues, for example if your billing method is not working.

3. Information disclosure

3.i) Your Use of the Service

Your Personal Data will be displayed on your personalized account page, accessible through the Service. If you have a multi-user "Company" account then the administrator of your Company account will be able to see your Personal Data alongside all other sub-accounts contained within the parent account for the purposes of administering the account.

When you send a Materials link to an End-User, that End-User will be able to see the User's name and email address for the purpose of replying to you and identifying who sent them the link. All links are unique and it is your and your End-Users' responsibility to contain the manner and extent to which this Personal Data may be shared further. If you choose to share further Personal Data in the custom message you set for the Materials link or any other comments pertaining to a specific Materials item please be aware this is done at your own discretion and at your own risk in terms of data containment.

3.ii) Service providers and employees

We use external Service providers for certain internal functions, for example storing sales contacts in the HubSpot CRM. Other service providers who provide support, advertising platforms, analytics, management and payment processing may also need to access your Personal Data as is required to provide the Service to you. Our employees too may need to access your Personal Data as needed to provide the Service.

3.iii) Acquisition or merger

If we are acquired or involved in a merger, your information may be transferred as part of any such transaction. You will be informed of any such occurrence and what your choices are moving forward.

4) Data Retention

We keep your Personal Data for as long as needed by law, to fulfill the functions specified in this policy, or as long as your User account is active or as required to provide you our Service - whichever is the longest. You can request we delete your account and information at any time by emailing us at hello@sharepanel.co.

5) Changing Your Information

As a User you may update your Personal Data at any time in your account settings on the Service.

6) GDPR

6.i) Share Panel as Processor

Share Panel is the data controller for the processing of your Personal Data. We act as the data processor for Personal Data that we process on behalf of our Users. You can contact us in respect to acting as a data controller and processor at hello@sharepanel.co.

6.ii) Your Rights

You have the following rights in relation to your Personal Data:

• Right of access: when asked we will confirm if we are processing your Personal Data and provide a copy of it
• Right to erasure: You can ask us to delete your Personal Data at any time.
• Right to restrict processing: You can ask us to restrict the processing of your Personal Data in some circumstances, for example if you dispute the accuracy of the data.
• Right to rectification: If your Personal Data is incorrect you can ask us to correct it. We will inform anyone of the corrected information that had the incorrect information shared with them where possible if that is your wish.
• Right to object: You may ask us at any time to stop processing your Personal Data
• Right to data portability: You can ask us to supply you with a copy of your Personal Data in a machine-readable format and reuse it elsewhere.
• Right to complain to your data protection authority: If you have a complaint about our privacy procedures you can report it.

7) Security

We use common security practices to protect your Personal Data. For example your password is stored in an encrypted format. No method of electronic transmission can ever be 100% secure but we take reasonable steps to try and protect it to the best of our ability. If you would like more information about our security practices please contact us at hello@sharepanel.co.

8) Sales of Personal Data

We do not sell Personal Data.

9) Changes to our Privacy Policy

This policy may change occasionally. If we change it we will provide you with notice of the change via email.

10) More information

If you have any further queries about this Privacy Policy please email us at hello@sharepanel.co.