General Privacy Policy

General Privacy Policy

Effective Date: March 4, 2021

This privacy policy was last modified on March 4, 2021. This Privacy Policy may change, so please check this web page for updates to our Privacy Policy. This privacy statement describes how Shibumi.com, Inc. (“Shibumi”) collects and uses the personally identifiable information (“Personal Information”) you provide on our Web site, www.shibumi.com (“Website”), and our web-based strategy execution software platform (“Service”). It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. We will not use or share your Personal Information with anyone except as described in this Privacy Policy.

The policy of Shibumi is to respect and protect the personal data collected or maintained by or on behalf of Shibumi.  As part of our commitment to this policy, Shibumi adheres to the principles of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (Privacy Shield), but does not rely on them as a legal basis for the transfers of personal data (in light of the judgement of Court of Justice of the EU in Case C-311/18 and the opinion issued by the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland.  These principles are set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU) and the United Kingdom (UK) and Switzerland, to the United States in reliance on Privacy Shield.  Shibumi has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Neither our Website nor our Service are intended for children and we do not knowingly collect data relating to children.

Collection of Information

We collect several types of Personal Information

  • Identity Dataincludes name and other identifiers
  • Contact Dataincludes email address and telephone numbers.
  • Technical DataIP address, browser type, operating system, mobile carrier, your ISP, the URLs of sites from which you arrive or leave the Shibumi website, or sites that have embedded Shibumi platform technology
  • User Profile Dataincludes your username, password, and account preferences
  • Usage Dataincludes information about how you access and use our website and Service
  • Marketing Dataincludes your preferences in receiving communications from us and third parties

We gather information from our web site and other sources

When you visit our Website, we may collect Personal Information regarding your visit from your computer. Such information helps us to determine information about how you found our Website, the date that you visited our Website and search engines that may have led you to our Website. We collect this information in order to continually improve and enhance the functionality of www.shibumi.com and our Service.  We use this information because we have a legitimate business interest in understanding how our website is accessed, how it is used, and any problems users have with accessing the web site. We will keep this information for a reasonable length of time for those purposes.

In addition, we may collect Personal Information (including identity data, contact data and marketing data) through other channels, such as an exchange of information with a sales representative, voluntary web submission, contact information provided by a colleague, or an event registration form.  You do not need to provide this information. We use this information because we have a legitimate business interest in promoting our business and our Service. We will keep this information for a reasonable length of time that lets us realize these goals and understand the impact of our communications and any marketing offers that we may make.

We gather information through cookies and other tracking technologies

As is true of most Web sites, we gather certain technical data automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information to analyze trends, to administer the site, to provide audit trails, to track users’ movements around the site and to gather demographic information about our user base as a whole for the purpose of improving delivery of our Service.

We do link this automatically-collected data to personally identifiable information. IP addresses are tied to personally identifiable information to ensure security-access control and enable comprehensive security-audit functionality.  We will keep this information for a reasonable length of time to complete performance analysis, site administration and gather demographic information about our user base. We use a third-party tracking service Google Analytics that uses scripts to track non-personally identifiable information about visitors to our site in the aggregate. We capture timing information related to performance of the service, page loads to identify trends and popularity of certain features and functions of the service, as well as geographic information to enable us to provide high-performance load balancing and low latency user access.

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this site. Currently, we use session ID cookies to make it easier for you to navigate our site, including storing your authentication ID, so you don’t have to login more than once and tracking and targeting the interests of our users to enhance the experience on our site. The Shibumi session ID cookie expires after 3 hours of inactivity.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please refer to the help and support area on your internet browser for instructions on how to block or delete cookies. However, if you use your browser settings to block all cookies you may not be able to access all or parts of our site.

We gather information from all users of our Service

If you, your employer or a third party chooses to use our Service, we will use your Personal Information including for the purposes of providing, managing and administering the Service to you.

Prior to your use of our Service, an authorized user of the Service may add you as a user entitled to access specific capabilities and information on the Service.  The user adding you for the first time will provide us certain Personal Information, including name and e-mail address.  We will provide you with a unique user identification (an e-mail address) and send you an account activation email to access the Service and provide user profile information (including user identification and password).  You can also update or confirm contact information.  You have access to your user profile and can update or correct Personal Information in the profile at any time.

Once your Personal Information has been entered into your profile, that Personal Information is viewable by other users of the Service with access to specific capabilities and information.  You may then receive e-mails relating to your use of the Service, such as alert notifications.  Your Personal Information will be maintained as part of a Service-wide user directory.  In addition, you may provide us with user-generated content (which may include Personal Information) for the purpose of conducting business using the Service.

We use the information described above to deliver the Service and help you access and manage your account.  We use this information because we have a legitimate business interest in delivering the Service we are contracted to provide to you, your employer or a third party.  We will keep this information for as long as we are contracted to provide the Service.

We track usage and activity on the Service for all users

As a function of the Service and in order to conduct internal analysis of use of the Service, Shibumi also will maintain a history of your access to the Service, and certain actions taken by you while accessing the Service. This includes maintaining a log of users’ IP addresses, the websites from which users access the Service, the type of web browsers used to access the Service and the browser’s settings that may affect Service performance.

This usage and activity data will be recorded and used internally by authorized Shibumi employees for customer support, system performance tracking and other activities.  In addition, this information may also be made available to authorized users, pursuant to their role as administrator for a particular customer using the Service.

We use this information because we have a legitimate business interest in supporting our customers and understanding how our Service is accessed and used.  We will keep this information for a reasonable length of time that allows us to provide the Service that we have contracted to deliver for you, your employer, or with a third party.

We gather non-personally identifiable information for advertising

We partner with a third-party ad network to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

Sharing, Protecting and Controlling Personal Information

You may opt-out of marketing and product information communications

You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or you can contact us at privacy@shibumi.com. Although you may opt-out of receiving promotional information from Shibumi, we may still contact you in connection with any transactions, activities, solicitations, relationships and requests made through our service or through www.shibumi.com.

We share certain information with third parties

We will share your personal information with data processors that provide services or integrations with the Shibumi application only in the ways that are described in this privacy statement. We do not sell your personal information to third parties. In cases of onward transfer to third parties of data of EU, UK and Swiss individuals we will protect that information as described in this Privacy Policy an in accordance with applicable law.  We use contractual protections for the transfer of personal information among various jurisdictions (including, for example, the European Economic Area Regulations). If third party agents process personal data on our behalf in a manner inconsistent with the principles of either Privacy Shield framework, we are potentially liable.  We may provide your personal information to companies that provide services to help us with our business activities such as offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us. Upon your consent and if enabled in your enterprise, we will share your personal information with third parties that provide integrations with the Shibumi application.

We may also disclose your personal information for other reasons, including:

  • To comply with a lawful request by public authorities, including to meet national security or law enforcement requirements
  • When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request,
  • If Shibumi is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information,
  • To any other third party with your prior consent to do so.

We carefully protect your personal information

The security of your personal information is important to us. When you enter sensitive information (such as login credentials), we encrypt the transmission of that information using 256-bit transport layer security technology (TLS).

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. There is no guarantee that information may not be accessed, copied, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications at all times.

If you have any questions about security on our Web site, you can contact us at privacy@shibumi.com.

You may access third party social media sites through Shibumi’s web site

Our Web site includes Social Media Features, such as the LinkedIn “following” and Facebook links. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

We allow you to update or remove your personally identifiable information

If your Personal Information changes, or if you no longer desire our service, you may correct, delete/remove, or deactivate by making the change on our member information page or by emailing our Customer Support at support@shibumi.com or by contacting us by telephone or postal mail at the contact information listed below. An acknowledgment of your request will be made within 7 days of receipt of notice and a response will be communicated within 30 days of receipt (or as required by applicable law).

We retain your information for only as long as required

We will retain your information for as long as your account is active or as needed to provide you or your sponsoring organization services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at support@shibumi.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, improve our service offering, and enforce our agreements.

Rights around Personal Information for EEA Residents

If you are a resident of the EEA, you have certain rights under data protection laws in relation to your personal data. You have the right to:

Request access to your Personal Information, enabling you to receive a copy of the personal information we hold about you

Request correction of the Personal Information that we hold about you, enabling you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us

Request erasure of your Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request

Object to processing of your Personal Information where we are relying on a legitimate business interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground based on your belief that it impacts on your fundamental rights and freedoms

Request restriction of processing of your Personal Information under certain circumstances

Request the transfer of your Personal Information to you or to a third party in a structured, commonly used, machine-readable format

Withdraw consent at any time where we are relying on consent to process your Personal Information, acknowledging that this will not affect the lawfulness of any processing carried out before you withdraw your consent, and that we may not be able to provide our Service to you (or your employer) if you withdraw your consent

If you would like to exercise or discuss any of these rights, please contact us at support@shibumi.com.  An acknowledgement of your request will be made within 7 days of receipt of your email and a response will be communicated within 30 days of your request. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and provide updates on timing.

Additional Information

We process, store and access information in multiple countries and jurisdictions

Each customer deployment of the Service is based in a particular Amazon Web Services instance (Americas, Europe or Asia).  Data associated with that specific deployment will be processed and stored in the designated Amazon Web Services instance.  If you are not certain where your deployment is hosted, please contact support@shibumi.com or your account team.

Depending on where you are resident, we may transfer Personal Information and usage statistics that we collect about you from your country or jurisdiction to other locations where our data and Service are stored, provided and supported including the United States. For any such transfer, Shibumi takes necessary contractual measures to ensure that your personal information receives an adequate level of protection (including, for example standard contractual clauses) and in accordance with applicable laws. By using the Service, you consent to the transfer of information to the U.S. and the use and disclosure of information about you, including Personal Information, as described herein.

We will provide notification of changes to our Privacy Policy

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on shibumi.com prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

All Shibumi employees and contractors are responsible for implementing and maintaining this Privacy Policy

All Shibumi employees and contractors have been made aware of this Privacy Policy, with appropriate responsibilities communicated to specific employees.  Shibumi’s Privacy Code of Conduct is available on request.

Contact us to resolve any privacy issues

If you have any questions or comments about this Privacy Policy, or if you would like us to update the information, we have about you or your preferences, please contact us by email or postal mail at the one of the addresses below:

US Corporate Headquarters:

Shibumi.com, Inc.
50 Washington Street
Suite 302E
South Norwalk, CT 06854
privacy@shibumi.com

In the E.U., Shibumi has appointed VeraSafe as its representative for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union.  If you are in the EEA, VeraSafe can be contacted in addition to or instead of privacy@shibumi.com, only on matters related to the processing of personal data.  To make such an inquiry, please contact VeraSafe using this contact form or via telephone at +420 228 881 031

Alternatively, VeraSafe can be contacted at:

VeraSafe Ireland Ltd.

Unit 3D North Point House

North Point Business Park

New Mallow Road

Cork T23AT2P

Ireland

In the United Kingdom, Shibumi has appointed VeraSafe as its representative for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation.  If you are in the United Kingdom, VeraSafe can be contacted in addition to or instead of privacy@shibumi.com, only on matters related to the processing of personal data.  To make such an inquiry, please contact VeraSafe using this contact form or via telephone at +44 (20) 4532 2003

Alternatively, VeraSafe can be contacted at:

VeraSafe United Kingdom Ltd.

37 Albert Embankment

London SE1 7TL

United Kingdom

Shibumi has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

If your complaint is not satisfactorily addressed, and your inquiry or complaint involves human resource data, you may have your complaint considered by an independent recourse mechanism: for EU/EEA Data Subjects, a panel established by the EU data protection authorities (“DPA Panel”), and for Swiss Data Subjects, the Swiss Federal Data Protection and Information Commissioner (“FDPIC”). To do so, you should contact the state or national data protection or labor authority in the jurisdiction where you work. Shibumi agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel and the FDPIC.

Should your complaint remain fully or partially unresolved after a review by Shibumi, BBB EU PRIVACY SHIELD and the relevant DPA, you may be able to, under certain conditions, seek arbitration before the Privacy Shield Panel. For more information, please visit www.privacyshield.gov.

Shibumi is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).