ShortList, LLC understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Sites and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
2.1 Our Sites, shortlist.io and growthpros.io, are owned and operated by shortlist, LLC, a limited liability company registered in the United States of America under EIN 61-1914741, whose mailing address is 2200 Benjamin Franklin Parkway, Philadelphia Pennsylvania 19130.
4.2 date of birth;
4.4 business/company name
4.5 job title;
4.7 contact information such as email addresses and telephone numbers;
4.8 demographic information such as postcode, preferences and interests;
4.9 financial information such as credit / debit card numbers;
4.10 IP address (automatically collected);
4.11 web browser type and version (automatically collected);
4.12 operating system (automatically collected);
4.13 a list of URLs starting with a referring site, your activity on Our Sites, and the site you exit to (automatically collected);
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679)(GDPR). For more details on security see section 6, below.
5.2 We use your data to provide the best possible products and services to you. This includes:
5.2.1 Providing and managing your Account;
5.2.2 Providing and managing your access to Our Sites;
5.2.3 Personalizing and tailoring your experience on Our Sites;
5.2.4 Supplying Our products and services to you;
5.2.5 Personalizing and tailoring Our products and services for you;
5.2.6 Responding to communications from you;
5.2.7 Supplying you with email newsletters and alerts that you have subscribed to (you may unsubscribe or opt-out at any time by Insert Description of Unsubscription Method;
5.2.8 Market research;
5.2.9 Analyzing your use of Our Sites and gathering feedback to enable Us to continually improve Our Sites and your user experience;
5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.
5.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone and/or text message and/or post with information, news and offers on Our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data.
6.2 Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Sites and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements.
6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Sites.
6.4 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7.1 We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
7.2 We may compile statistics about the use of Our Sites including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.3 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required by any legally binding request that is made of Us.
8.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
9.1 When you submit information via Our Sites, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emailsand at the point of providing your details and/or by managing your Account).
10.1 You may access certain areas of Our Sites without providing any data at all. However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain data.
10.3 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at firstname.lastname@example.org or using the contact details below in section 15.
12.2 By using Our Sites you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Sites.
12.3 All Cookies used by and on Our Sites are used in accordance with current English and EU Cookie Law.
12.4 Before Cookies are placed on your computer or device, subject to section 12.5 and/or section 12.8, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Sites may not function fully or as intended.
12.5 Certain features of Our Sites depend on Cookies to function. The United States of America and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.9, but please be aware that Our Sites may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
a) SESSION COOKIES VS. PERSISTENT COOKIES Cookies can either be “session Cookies” or “persistent Cookies”. Session Cookies are temporary Cookies that are stored on your device while you are visiting our Website or using our Service, whereas “persistent Cookies” are stored on your device for a period of time after you leave our Website or Service. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie. We use persistent Cookies to store your preferences so that they are available for the next visit and to keep a more accurate account of how often you visit our Service, how often you return, how your use of the Service may vary over time. We also use persistent Cookies to measure the effectiveness of advertising efforts. Through these Cookies, we may collect information about your online activity after you leave our Service.
b) THIRD-PARTY COOKIES Some Cookies are placed by a third party on your device and may provide information to us and third parties about your browsing habits (such as your visits to our Service, the pages you have visited and the links and advertisements you have clicked). These Cookies can be used to determine whether certain third party services are being used, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. We do not control third-party Cookies, however, users may opt out from certain third-party Cookies (e.g. Retargeting/Advertising cookies) by using our TrustArc cookie management solution (see Cookie Settings below).
c) FURTHER INFORMATION Further information about Cookies can also be found at http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm, https://ico.org.uk/for-the-public/online/cookies/, and http://www.allaboutcookies.org/.
d) WHAT TYPES OF COOKIES DO WE USE AND FOR WHICH PURPOSES?
12.6.1 ESSENTIAL COOKIES Essential (or “Required”) Cookies that are required for providing you with features or services that you have requested. For example, certain Cookies enable you to sign in to secure areas of our Website or use a shopping cart feature within our Service. Disabling these Cookies may make certain features and services unavailable.
12.6.2 FUNCTIONALITY COOKIES Functional Cookies are used to record your choices and settings regarding our Service, maintain your preferences over time and recognize you when you return to our Service. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
12.6.3 PERFORMANCE/ANALYTICAL COOKIES Performance/Analytical Cookies allow us to understand how visitors use our Website and Service such as by collecting information about the number of visitors to the Website, what pages visitors view on our Website and how long visitors are viewing pages on the Website. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Service’s content for those who engage with our advertising.
12.6.4 RETARGETING/ADVERTISING COOKIES Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.
12.6.5 COOKIE SETTINGS You can decide whether or not to accept Cookies. One way you can do this is through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some Service and functionalities may not work.
12.6.6 To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ or http://www.allaboutcookies.org/.
12.6.7 We also allow you the ability to opt out of certain types of Cookies by clicking on the cookie banner when you first enter the applicable website (for EU users), or by clicking here to adjust your cookie settings.
12.7 Our Sites use analytics services provided by Google, WordPress and Amazon. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Sites. This, in turn, enables Us to improve Our Sites and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however, whilst Our use of them does not pose any risk to your privacy or your safe use of Our Sites, it does enable Us to continually improve Our Sites, making it a better and more useful experience for you.
12.8 The analytics service(s) used by Our Sites use(s) Cookies to gather the required information. Certain of these Cookies may be placed immediately when you first visit Our Sites and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.9.
12.9 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
12.10 You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Sites more quickly and efficiently including, but not limited to, login and personalization settings.
12.11 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
Under the GDPR, you have:
13.1 the right to request access to, deletion of or correction of, your personal data held by Us;
13.2 the right to complain to a supervisory authority;
13.3 be informed of what data processing is taking place;
13.4 the right to restrict processing;
13.5 the right to data portability;
13.6 object to the processing of your personal data;
13.7 rights with respect to automated decision-making and profiling (see section 14 below).
14.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
14.2 The right described in section 14.1 does not apply in the following circumstances:
a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;
b) The decision is authorised by law; or
c) You have given you explicit consent.
14.3 Where We use your personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organizational measures necessary to minimize the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
14.4 We currently make the following automated decisions: None.
14.5 We currently profile your personal data for the following purposes: Sales, Marketing, Service Operations