SheerID Global Privacy Policy
Last Updated: April 18, 2023
This Privacy Policy explains how SheerID, Inc. and its subsidiaries and affiliates companies (“SheerID”, “we”, or “us”) collects, uses, and discloses information about you. We strive to protect and respect your privacy.
This Privacy Policy applies when you use our websites and other online products and services that link to this Privacy Policy (collectively, the “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us directly.
This Privacy Policy also applies to our Audience Development Product and Services. You can read more about AD Services here and about how SheerID collects, uses, and discloses information about you as part of this service here.
This Privacy Policy does not apply to information:
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(a)processed by SheerID on behalf of other companies utilizing SheerID’s verification platform to verify your identity for the purposes of providing you with a discount or other offers (collectively, “Clients”); or
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(b)collected by any third party, including through any application or content (including advertising) that may link to, be accessible from, or present in the Services (collectively, “Third Party Services”).
If you have any questions about how Clients or Third Party Services collect, use, or disclose your information, please review their respective privacy policies.
We may change this Privacy Policy from time to time. If we make changes, we revise the date at the end of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
Contents
How We Collect Your Information
Transfer of Information to the United States and Other Countries
Your Choices About How We Use and Disclose Your Information
Disclosures for California Residents
Your California & Virginia Privacy Rights & Choices
Additional Disclosures for Individuals in Europe
How We Collect Your Information
Information You Provide to Us
We collect information that you provide directly to us. For example, you share information with us when you subscribe to our services or request further information, fill in a form, complete a survey, make a purchase, communicate with us via third party platforms, participate in a contest or promotion, request customer support, search on our website, or otherwise communicate with us. The types of personal information we may collect include your name, email address, phone number, log-in credentials, postal address, credit card or other payment information, or any other information you choose to provide.
Information We Collect Automatically When You Interact with Us and How We Collect It
When you access our Services, website, or otherwise transact business with us, we automatically collect certain information, including:
- Activity Information: We collect information about your activity in relation to our Services, such as internet traffic data, website access times, website pages viewed, links clicked, logs, and other communication data. This may include the website page(s) you visited before navigating to our Services and the resources that you access and use on our Services.
- Transactional Information: When you access a discount or offer through our website, we may collect information about the transaction, such as product details, and the date and location of the transaction.
- Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version.
- Location Information: In accordance with your device permissions, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Your Choices section below for details).
- Information Collected by Cookies and Similar Tracking Technologies: We (and our Third Party Services) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy and the Your Choices section below.
Information We Collect from Other Sources
We obtain information from third-party sources. For example, as part of our Services and at the direction of our Clients, we may collect and process information about you from identity verification services, employment or academic verification services, social networks, credit bureaus, advertising networks, data analytics providers, and mailing list providers. Additionally, if you create or log into your SheerID account through a third-party platform, we will have access to certain information from that platform, such as your unique user identification, email address, and first and last name in accordance with the authorization procedures determined by such platform.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your interests or personalize your user experience and what Services we show you based on your industry, company, or how you interact with our website.
How We Use Your Information
We use the information that we collect about you or that you provide to us, including any personal information:
- To present, customize, and personalize our website and its contents for you;
- To present, customize and personalize your user experience, including the interactive chat features, and what Services we show you when you visit and interact with our website;
- Process transactions and send you related information, including confirmations, receipts, invoices, and customer experience surveys;
- Personalize and improve your experience on our Services;
- Send you technical notices, security alerts, and support and administrative messages;
- Respond to your comments and questions and provide customer service;
- Communicate with you about products, services, and events offered by us and others that we think will interest you. If you do not want us to use your information in this way, see the Your Choices section below for information about how to opt out of these communications at any time;
- Monitor and analyze trends, usage, and activities in connection with our Services;
- Personalize the advertisements you see when you use our Services based on information provided by our advertising partners;
- Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of SheerID and others;
- Debug to identify and repair errors in our Services;
- Comply with our legal and financial obligations; and
- Carry out any other purpose described to you at the time the information was collected.
How We Share Your Information
We may disclose personal information in the following circumstances or as otherwise described in this privacy policy:
- We share personal information to fulfill the purpose for which you provide it. If you seek to accept a benefit from one or more of our Clients that is advertised or located on our website, we will share your information with the Clients. Your information may be used by our Clients to provide you with products or services or to inform you of additional products or services.
- We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, and marketing and advertising. Each is bound by contractual obligations to keep personal information confidential, secure, and use it only for the purposes for which we disclose it to them.
- We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
- We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of SheerID, our users, the public, or others.
- We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
- We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, acquisition, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our business.
- Personal information is shared between and among SheerID and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
- We share personal information at your direction.
We may also share aggregated or de-identified information that cannot be reasonably used to identify you.
Analytics & Tracking
Analytics
We allow others to provide analytics services on our behalf across the web. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by SheerID and others to, among other things, analyze and track data, determine the popularity of certain content, customize or personalize the Services shown to you on our website, and better understand your online activity. Some of the activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under certain laws. You can opt out of having your personal information used or disclosed for these purposes via cookies and similar technologies on our website by visiting the Privacy Center and sliding the toggle that states “off” or by visiting our website with a legally recognized opt-out preference signal, such as the Global Privacy Control. To learn more about the choices available to you with respect to these practices, visit the Privacy Center.
For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.
Online Tracking
We also may use these technologies to collect information about your online activities over time and across third-party websites. SheerID does not currently respond to web browser Do Not Track (DNT) signals.
Transfer of Information to the United States and other Countries
SheerID is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.
Your 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:
- Account Information. You may update and correct certain account information at any time by logging into your account, emailing us at [email protected], or accessing your user preferences at Preference Center. If you wish to delete your account, please email us at [email protected], but note that we may retain certain information as required by law or for our legitimate business purposes.
- Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. For more information about cookies and how to disable them, see our Cookie Policy.
- Promotional Offers from SheerID. If you do not wish to have your contact information used by SheerID to promote our own products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Disclosures for California Residents
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We DO NOT disclose your personal information to third parties for their direct marketing purposes.
The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.
California Consumer Privacy Act
In the preceding 12 months, we have collected and disclosed the following categories of personal information: identifiers, commercial information, Internet or other electronic network activity information, Characteristics of protected classifications under California or federal law, and professional or employment related information. For details about the precise data points we collect and the categories of sources of such collection, please see the How We Collect Your Information section above. We collect personal information for the business and commercial purposes described in the How We Use Your Information section above.
For a list of categories of personal information we have disclosed in the preceding 12 months to our service providers and vendors for business purposes, click here.
Your California & Virginia Privacy Rights & Choices
If you are a California or Virginia resident, you may have certain data rights under the California Privacy Rights Act (CPRA) or the Virginia Consumer Data Protection Act (VCDPA), including the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose and access your personal information, including in a portable format, (2) request deletion of your personal information, (3) request correction of inaccurate personal information, (4) opt out of any “sales” of your personal information that may be occurring; and (5) not be discriminated against for exercising these rights.
You may make these requests by emailing [email protected] or calling 1-833-317-3372. We will verify your request by asking you to provide information related to your recent interactions with us, such as your name, physical and/or email address, telephone number, or other identifying information. We will not discriminate against you if you exercise your rights under the CCPA or the VCDPA. Please note that this number is for privacy inquiries only. For questions regarding how to complete your verification request, please visit our help center.
If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us by emailing us at [email protected] or calling 1-833-317-3372.
You may also have the right to appeal the denial of any of these rights by submitting a form that will be provided to you if we deny a data request. Depending on your data choices, certain services may be limited or unavailable.
We do allow our advertising partners to collect certain device identifiers and electronic network activity via our Services to show ads that are targeted to your interests. To opt out of having your personal information used for targeted advertising purposes, please see the Analytics section above.
Data Retention
We store personal data associated with customer accounts for as long as an account remains active. If you close your account, we will delete your account data within 30 days; otherwise, we will delete your account data after two years of inactivity.
We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
Additional Disclosures for Individuals in Europe
If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.
Legal Basis for Processing
When we process your personal data, we will do so in reliance on the following lawful bases:
- To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).
- When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services and to communicate with you).
- To comply with our legal obligations (e.g., to maintain a record of your consents, track those who have opted out of marketing communications, and comply with other regulatory obligations).
- When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.
Where we are processing personal data on behalf of our Clients, the Client is the Controller and SheerID is a Processor, as those terms are defined under the applicable privacy laws. You are encouraged to review the Client’s privacy policy directly for information concerning the collection, use, and processing of your personal data.
Disclosures related to the eduGAIN / Geant Data Protection Code of Conduct can be found here.
We are committed to the Data Protection Code of Conduct which describes an approach to meet the requirements of the EU GDPR in federated identity management.
Data Subject Requests
Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please contact us at [email protected] or visit the Privacy Center.
Questions or Complaints
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:
For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: https://ico.org.uk/global/contact-us/
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
Data Security
We have implemented 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 your (or where you have chosen a) password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. 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 the Services.
Contact Information
If you have any questions or comments about this notice, the ways in which SheerID collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under applicable law, please do not hesitate to contact us at:
SheerID, Inc.:
E-mail address: [email protected]
Postal address: 1300 SW 5th Avenue, Suite 2100, Portland, OR 97201 USA
Web Form: https://www.sheerid.com/contact-us-form/
Data Protection Officer:
Greg Damon is SheerID’s Data Protection Officer. On matters related to the processing of personal data, Greg Damon can be contacted at [email protected].
EU Representative:
Francois Rychlewski is SheerID’s Article 27 (GDPR) representative in the European Union. On matters related to the processing of personal data, Francois Rychlewski can be contacted in addition to SheerID. Francois can be contacted at [email protected]..
Last Updated: April 18, 2023