BUSINESS

Privacy Policy

PRIVACY POLICY

Last modified: May 24, 2018

Introduction. Sortly Inc. (the “Company” or “we”) respects your privacy and we are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the website www.sortly.com (this “Website“) or through the “Sortly” productivity app (the “App“), and our practices for collecting, storing, processing, using, maintaining, transferring, sharing, protecting and disclosing that information.

This policy applies to information we collect:

(a) on this Website;

(b) in e-mail, text and other electronic messages between you and this Website;

(c) through the App that you download from this Website or through Apple’s App Store or Google’s Play Store (each, the “Store”), each of which provides dedicated non-browser-based interaction between you and this Website or the Store (as applicable); or

(d) when you interact with our advertising and applications on third-party websites and services, whether or not those applications or advertising include links to this policy. It does not apply to information collected by: (i) us offline or through any other means, including on any other website operated by the Company or any third party; or (ii) any third party, including through any application or content (including advertising) that may link to or be accessible from or on this Website.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, YOUR CHOICE IS NOT TO USE THIS WEBSITE OR DOWNLOAD OR USE THE APP. BY ACCESSING OR USING THIS WEBSITE OR THE APP, YOU AGREE TO THIS PRIVACY POLICY. THIS POLICY MAY CHANGE FROM TIME TO TIME. YOUR CONTINUED USE OF THIS WEBSITE OR THE APP AFTER WE MAKE CHANGES IS DEEMED TO BE ACCEPTANCE OF THOSE CHANGES, SO PLEASE CHECK THE POLICY PERIODICALLY FOR UPDATES.

Data Controller.Sortly Inc., a Delaware corporation, will be deemed “data controller” for regulatory purposes, as applicable.

Our Policy Towards Children. This Website and the App are not intended for children under 16 years of age. No one under age 16 may provide any information to or on this Website or the App. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or the App, or on or through any of its or their features/register on this Website or the App, use any of the interactive or public comment features of this Website or the App, or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we may have any information from or about a child under 16, please contact Sortly Support.

Information We Collect About You and How We Collect It.We collect several types of information from and about users of this Website or the App, including information:(a) by which you may be personally identified, such as name, postal address, e-mail address, telephone number, payment details or GPS coordinates (“personal information”);(b) that is about you but individually does not identify you; and/or(c) about your internet connection, the equipment you use to access this Website or the App and usage details.

We collect this information:(i) directly from you when you provide it to us; (ii) automatically as you navigate through this Website or use the App; and (iii) from third parties, for example, our business partners, including the Store. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us. The information we collect on or through this Website or the App may include:

(a) Information that you provide by filling in forms on this Website or the App. This includes information provided at the time of registering to use this Website or the App, subscribing to or paying for our service, posting material, or requesting further services (including, without limitation, backup or password recovery services, or payment services, that we may provide through third parties). We also may ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with this Website or the App.

(b) Records and copies of your correspondence (including e-mail addresses), if you contact us.

(c) Your responses to surveys that we might ask you to complete for research purposes.

(d) Details of transactions you carry out through this Website or the App.

(e) Your search queries on this Website or the App.

(f) Any other information that you provide to third parties that are associated with our service, the App or this Website (whether or not you link to them through this Website or the App), including, without limitation, the Store, Dropbox, Apple iCloud, Google Drive, Stripe and other payment processors or storage providers.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of this Website, or transmitted (publicly or privately) to other users of this Website, the App or third parties, such as by way of example but without limitation, a portion of your database to your friends, family or co-workers through Dropbox or other third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we may limit access to certain pages or we may allow you to set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of this Website or the App with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

If you provide us information about third parties that have provided such information to you, you agree to inform them and seek their consent to sharing, disclosing and transferring that information to us and allowing us to access, use, retain and store such information on our systems. If such information relates to sensitive personal information, you agree to obtain affirmative, express consent from each such individual before it is shared with us.

Usage Details, IP Addresses, Cookies and Other Technologies. As you navigate through and interact with this Website or the App, we may automatically collect certain information about your equipment, browsing actions and patterns, including:(a) details of your visits to this Website or the App, including traffic data, location data, logs and other communication data and the resources that you access and use on this Website or the App; and(b) information about your computer and internet connection, including your IP address, operating system and browser type. The information we collect automatically is statistical data. It helps us to improve this Website and the App and to deliver a better and more personalized service by enabling us to:(i) estimate our audience size and usage patterns;(ii) store information about your preferences, allowing us to customize this Website and the App according to your individual interests; (iii) speed up your searches; and (iv) recognize you when you return to this Website or the App.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or phone. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of this Website or the App. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to this Website or the App.

Flash Cookies. Certain features of this Website or the App may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on this Website or the App. Flash cookies are not managed by the same browser settings as are used for browser cookies.

Web Beacons. Pages of this Website or the App may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

How We Use Your Information. We use information that we collect about you or that you provide to us, including any personal information:(a) to present this Website, the App and their contents to you;(b) to provide you with information, products or services that you request from us;(c) to fulfill any other purpose for which you provide it;(d) to provide you with notices about your account;(e) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;(f) to notify you about changes to this Website, the App or any products or services we offer or provide though it(g) in any other way we may describe when you provide the information; and(h) for any other purpose with your consent.

Disclosure of Your Information.We may disclose aggregated information about our users without restriction.We may disclose personal information that we collect or you provide as described in this privacy policy:(a) to our subsidiaries and affiliates;(b) to contractors, service providers and other third parties we use to support our business, including, without limitation, payment processors, accounting, legal and tax advisors, and vendors providing web hosting, web analytics and/or data enhancement services;(c) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about this Website or the App’s users is among the assets transferred;(d) to third parties to market their products or services to you if you have consented to or not opted out of these disclosures;(e) to fulfill the purpose for which you provide it; for example, if you share your database with your friends, family or co-workers or use any social applications to “tell a friend” about our App, we will transmit such contents and/or your e-mail address or other details to the recipients; or(f) for any other purpose disclosed by us when you provide the information.

We may also disclose your personal information:(i) to comply with any court order, law or legal process, including to respond to any government or regulatory request;(ii) to enforce or apply our Terms of Service and other agreements;or (iii) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company our customers or others.

Choices About How We Use and Disclose Your Information.We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information.

Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Marketing and Advertising. From time to time, we may send you updates, alerts, news, and mailings relating matters that we think may be of interest to you. Most messages we send will be via email. For some messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

If you are in the EEA, we will only send you marketing messages if you have given us your consent to do so. If you do not want to receive messages from us, you will be able to tell us when we first collect your contact details or by refusing or withdrawing your consent. You can also change your preference at a later date by clicking on the unsubscribe link at the bottom of our messages, visiting our preference settings to adjust your communication preferences, or by emailing us at support@sortly.com.

Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communication relating to the provision of our services.

Internet Based Advertising. We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services to collect information about your use of our services over time so that they may play or display ads on our services, on other websites, apps or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.

We may also use certain forms of display advertising and other advanced features through Google, Facebook and other social media sites. These features enable us to use first party cookies (such as the Google Analytics cookie) and third-party cookies together to inform, optimize, and display ads based on your past visit to our services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices

To learn about interest-based advertising and how you may be able to opt-out of some this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, the DAA’s resources at www.aboutads.info/choices and/or Your Online Choices at www.youronlinechoices.com/uk. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resource will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.

Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser setting, switch browsers or computers, or use another operating system, you will need to opt-out again.

Accessing and Correcting Your Information or Recovering Your Password.You may also send us an e-mail through the “Support” page of this Website or the App to request access to, correct or delete any personal information (including, without limitation, recovery of your password, if any) that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete your User Contributions from this Website or the App, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users or may be stored on third party applications, such as Dropbox, Evernote, Adobe or iCloud that you may use to store your User Contributions. Proper access and use of information provided on this Website, including User Contributions, is governed by our Terms of Service.

Your California Privacy Rights.California Civil Code Section § 1798.83 permits users of this Website or the App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to Sortly Support, or write us at: Sortly Inc., 314 Sea Cliff Ln., Redwood City, CA 94065.

Your Rights if You Are a Resident of EEA. If you are resident in the European Economic Area, under European law you have the following rights in respect of your personal information that we would hold:

(a) Right of Access. You have the right to obtain:

(i) confirmation of whether, and where, we are processing your personal information;

(ii) information about categories of personal information we are processing, the purpose for which we process your personal information and information as to how we determine applicable retention periods;

(iii) information about the categories of recipients with whom we may share your personal information; and

(iv) a copy of the personal information we hold about you.

(b) Right of portability. You have the right, in certain circumstances, to receive copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purpose for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

(f) Right to object. You have the right to object any processing based on or legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

If you are a resident in France, you also have the right to set guidelines for the retention and communication of your personal information after your death.

If you wish to exercise one of these rights please contact us at support@sortly.com.

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available here.

Residents in other jurisdictions may also have similar rights to the above. Please contact us at support@sortly.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.

Data Security.While no service is completely secure, we have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of this Website and/or the App, you are responsible for keeping your password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of this Website and/or the App, or sharing any of your information or database with your friends, family, co-workers or other third parties. The information you share in public areas may be viewed by any user of this Website and/or the App. Unfortunately, the transmission of information via the Internet is not completely secure. Although we take reasonable measures to protect your personal information in conformance with applicable laws, we cannot guarantee the security of your personal information transmitted to this Website. 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 this Website and/or the App.

While we take reasonable efforts to guard your personal information we knowingly collect directly from you, no security system is impenetrable. In addition, we cannot guarantee that any passively-collected personal information you choose to include in documents you store on our systems are maintained at levels of protection to meet specific needs or obligations you may have relating to that information. In particular, please be aware that we do not and cannot guarantee that our privacy policies and practices will comply with or conform to any minimum or higher privacy or data security standards that may be imposed on any materials or other content you store on Sortly. You are solely responsible for verifying and ensuring that our systems meet any such requirements imposed on you by applicable law, regulations, governmental, court or regulatory orders, or custom or usage of trade, and we are not responsible for any resulting consequences you may face if our systems or our service is found not to meet those specific legal, regulatory or governmental standards, except to the extent we otherwise expressly state in this privacy policy.

Changes to Our Privacy Policy.It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on this Website home page and/or through the App. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting this Website and/or the App, and this privacy policy to check for any changes.

Contact Information.To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Sortly Inc.
314 Sea Cliff Ln
Redwood City, CA 94065

Email: support@sortly.com