Adopted: November, 2022
Personal information we collect
We collect three categories of personal information – personal information you give us; personal information automatically collected from your use of the Services; and personal information from third-party sources.
Personal information you give us
Account data. When you register for an account with us, we require certain personal information to open your account, such as your name, email address, and password.
Profile data. We may also ask you to provide additional profile information to use certain features of the Services which may include street addresses, phone numbers, profile photos, city and, as applicable, biography. Certain parts of your profile (like your profile photos, city and biography) are part of your public profile page and will be publicly visible to others.
Product data. We collect information you provide in relation to a product listing, such as product details, availability dates, reviews, and uploaded photos.
Payment data. We collect your digital payment details, bank account or payment card numbers, and transaction information in connection with a potential or actual transaction, which may be processed and stored by one or more third party payment service providers or digital payments companies.
Identity verification data. In some instances, we may collect identity verification information such as a photograph or scanned copy of a driver’s license, passport, payment card, last four digits of your Social Security number, social media account information, or other forms of identification information. Where we request that you withhold certain information (such as obscuring or redacting aspects of identification information), please do so.
Communications. When you communicate with SHAP, including via phone, email, or chat, or use the Services to communicate with other users, we collect information about your communication and any information you choose to provide.
Personal information we automatically collect.
Usage data. We collect information about your interactions with the Services, such as the content you view, your searches, rental bookings you have made, how long you spent on a page or screen, sites from which you link or browse to in the Services, navigation paths between pages or screens, information about your activity on a page or screen, access time, duration of access, and other actions on the Services.
Location data. When you use certain features of the Services, we may collect information about your approximate location (e.g., city/town associated with your IP address). We may provide a location sharing feature. If you opt in to use such location sharing feature, we may collect the precise location information of your mobile device. Keep in mind that most mobile devices allow you to control or disable the use of location services by any application on your mobile device in the device’s settings menu.
Device data. We collect information about your computer or mobile device, such as its operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique device identifiers, or general location information such as city, state, or geographic area.
Rental data. We collect transactional information related to the rental bookings you engage in, the type of products being rented, the date and time of transactions, amounts charged, the location of the rental transaction (including, to the extent SHAP collects such information, the pick-up and return location) and other related details.
Cookies and similar technology. When you access the Services, the User may accept all cookies, accept only technical cookies or accept none. If accepted, we (including companies we work with) may place small data files on your computer or other device. These data files may be cookies, clear gifs, pixel tags, e-tags, “Flash cookies”, or other local storage provided by your browser or associated applications (collectively “Cookies”). At the present time, we comply with browser ‘Do-Not-Track’ signals.
Personal information we collect from third-party sources.
Background check services. To the extent permitted by applicable laws, SHAP may collect background information about you from public records, background check providers, or other screening services, including credit reports and information about criminal convictions or civil lawsuits. We may use your information, including your full name and date of birth, to obtain such reports.
Other sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data, fraud detection information, or data from credit bureaus and other third-party data providers.
We may combine the information about you that we receive from third-party sources with other information we have about you.
How we use your personal information
We use, store, and process your personal information to provide and improve the Services and for security and safety purposes. For example, we may use your information:
To provide the Services, including to:
- Provide and operate the Services
- Provide customer support
- Send you service, support, and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you at any telephone number, by placing a voice call or through text (SMS) or email messaging
- Facilitate your login to the Services via third-party identity and access management providers, such as Facebook, Google, and Apple
- Process transactions and send notices about your transactions
- Personalize or customize your user experience
- Enable you to communicate with other SHAP users, including by sending them messages or other information during the rental booking process
- Facilitate your referral invitations
- Track and utilize your user ratings
- Send your requests for reviews, for fraud detection and prevention, and for any purpose you authorize at the time of collection
- Administer referral programs, rewards, surveys, contests, or other promotional activities or sponsored events in which you participate
For research and development:
We may use your personal information to analyze and improve the Services and to develop new products and services, including by studying our user demographics of the Services. We may also create aggregated, de-identified, or other anonymous data from your personal information. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
For marketing and advertising:
We and our third party advertising partners may collect and use your personal information for marketing and advertising purposes:
Direct marketing. We may send you SHAP-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications.
For security and safety, including to:
- Verify your identity or authenticate information that you provide, including during account creation and password reset processes
- Resolve disputes, collect fees, and troubleshoot problems
- Detect, prevent, and/or remediate fraud, abuse, security incidents, or other potentially harmful, prohibited, or illegal activities
- Detect, prevent, or remediate violations of and enforce our Terms of Service and corporate policies.
- Manage and protect our information technology infrastructure
- Conduct investigations and risk assessments
- Conduct checks against databases and information sources (such as but not limited to public government databases)
- Perform creditworthiness and solvency checks
To comply with law:
We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities.
With your consent:
In some cases, we may specifically ask for your consent to process your personal information.
How we disclose your personal information
With your consent
We may share your information at your direction or with your consent.
Profiles, listings, and other public information
Your public listing page, when available, on the Services will always include some basic information, such as your user ID or name associated with your account, and for hosts, your public profile photo, the city and location where your products are located, your product listing description, product availability dates, transaction related information to allow our community to evaluate your reliability and responsiveness, and reviews or feedback about your products and possibly yourself. Your public listing page may also include aggregate demand information (such as number of page views over a period of time) and information about your cancellations, any complaints or failures to comply with terms of the rental transaction, such as returning the rental product late or damaged. The Services may also display the approximate geographic pick-up and return location of your products.
The Services may allow your public profile and public listing pages to be included in search engines, in which case your public profile and public listing pages may be indexed by search engines and may be published as search results.
Sharing between hosts and guests
SHAP enables hosts, the product owners, to rent their products to other individuals. If you agree to a rental booking through the Services, we may provide your information to the other party in that transaction as reasonably necessary to facilitate the transaction. For example, SHAP may provide your mobile phone number to facilitate communication, or your photograph to facilitate identification. We will also share the address where the product can be picked-up and returned and, once available, offer location tracking in real time to the applicable parties to facilitate the rental transaction. The other party may also send you text messages (such as to confirm pickup location). Standard telephone minute and text and data charges may apply.
We may share information with vendors and service providers who support the operation of the Services and business and who need access to such information to carry out their work for us (including, for example, web hosting, analytics, payment processing, email delivery, marketing, damage claims and customer support services). In some cases, the service provider may directly collect the information from you on our behalf. These service providers may use your personal information only as directed or authorized by us.
Third-party platforms and social media networks
If you have enabled features or functionality that connect the Services to a third-party platform or social media network (such as by logging in to the Services using your account with the third party, providing your API key or similar access token for the Services to a third party, or otherwise linking your Services account to a third-party’s services), we may disclose to the third-party platform or social media network the personal information necessary to facilitate the connection or that you authorized us to share. We do not control the third party’s use of your personal information.
We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
We may sell, transfer, or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization, or sale of assets, or in the event of bankruptcy or dissolution.
Responding to legal requests, preventing harm, and protecting our rights
We may disclose your personal information to courts, law enforcement, governmental or tax authorities, or third parties. We will make such disclosure to the extent we are required or permitted to do so by applicable law or where we consider such disclosure is reasonably necessary to comply with our legal obligations or legal process, to respond to claims asserted against us, and for the security and safety purposes described above. We may also disclose your information in response to valid legal requests relating to criminal investigations or alleged or suspected illegal activity or any other activity that may expose SHAP, you, or any other user, or to protect the rights, property, or personal safety of SHAP, our users, or others.
Additional Uses of Personal Information
We may collect and use your personal information for commercial purposes, including selling your personal information to third parties.
Categories of Personal Information collected for commercial purposes
We may collect personal information for commercial purposes from all three categories of personal information – personal information you give us; personal information automatically collected from your use of the Services; and personal information from third-party sources. Please see “Personal information we collect”, above.
Categories of Third Parties with which personal information may be sold
We may sell your personal data to the following categories of third parties:
- Business services/agency (for example data brokers)
- Entertainment (for example, companies that sell gaming consoles, systems and devices; movie and television studios; and, streaming services)
- Consumer Packaged Goods (for example, companies that sell personal and household products)
- Manufacturing (for example, companies that manufacture and produce products)
- Media and publishing (for example, magazines, retail catalogs)
- Retail (for example, department stores, hardware stores)
- Services-non professional (for example, consulting firms)
- Services-professional (for example, advertising agencies)
- Sports (for example, professional sports teams)
- Technology (for example, software and hardware providers, social media platforms)
Your preferences and choices
You can control the methods by which we may contact you about your account, your rental booking and listing activities, promotions, and announcements in the Notifications section within your SHAP account.
Opting out of marketing communications
You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message or as described in the message.
Correct and update
You can review, correct, update, and edit certain information that has been previously provided to us by you at any time by logging in to your account and reviewing your account settings and profile. You can also access or request a correction of your information by contacting us at Support@SHAP.market For your protection, we may need to verify your identity before implementing your request.
If you wish to close your account and request deletion of your personal information, please send an email to us at Support@SHAP.market.
Please note that we may be unable to delete information needed to comply with applicable laws, detect or prevent fraud, collect any fees owed, resolve disputes, assist with or process claims, troubleshoot problems, assist with any audits and investigations, to enforce our Terms of Service and Policies, and take other actions reasonably necessary, permitted, or required by applicable law. There may also be residual information that will remain within our databases, archival systems and other records, which will not be removed.
You can request a copy of your personal information pursuant to any information access rights that you may have under applicable laws in your account page. We may request proof of identification or re-authentication to verify your access request.
Users of our mobile application can disable the application’s access to the device’s location within the device’s settings.
Interest-based advertising choices
Your choices for limiting use of your personal information for interest-based advertising include:
Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device (e.g., Apple ID for Advertising or Google Advertising ID) for interest-based advertising purposes.
Using privacy plug-ins or browsers. You can block sites from setting cookies for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers.
Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies (but note we may work with companies that do not participate in these programs):
- European Interactive Digital Advertising Alliance (for users in the United Kingdom and Europe)
- Digital Advertising Alliance (for web users)
- Digital Advertising Alliance (for mobile app users)
- Network Advertising Initiative
Choosing not to share your personal information
Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or we later delete it at your request), we may not be able to provide you with the Services.
Third-party platforms and social media networks
If you choose to connect the Services to a third-party platform or social media network, such as by using the third party’s authentication service to log into your account on the Services, you may be able to control your settings through the third-party platform or social media network. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third party.
We employ a number of technical, physical, and organizational measures designed to protect information against unauthorized access, destruction, or alteration while it is under our control. However, no method of transmitting or storing information can be 100% secure and we cannot guarantee the security of your personal information.
Other important information
Cross border transfer
The Services may be controlled and operated from outside the United States. Your personal information may be used, stored, and processed in any country where we have facilities or in which we engage service providers. These locations may be outside of your state, province, or country of residence, and may have different and/or less protective data protection rules than those of your state, province, or country. As a result, this information may be subject to access requests from governments, courts, regulatory agencies, security authorities, or law enforcement in those jurisdictions according to the laws in those jurisdictions.
We ask that you not send us, and you not disclose, any sensitive information (e.g., passport information, information related to racial or ethnic origin, or health information) on or through the Services or otherwise to us unless specifically requested.
The Services are not intended for anyone under the age of 18 and we do not knowingly collect personal information from users under the age of 18. If a child under the age of 18 has already provided us with personal information, his or her parent or guardian may contact us to request that we delete it.
Third-party privacy practices
SHAP welcomes your questions and comments about privacy. Please feel free to contact us at our address:
1151 Walker Rd, PMB 315
Dover, DE 19904
You may also email us at Support@SHAP.market.
Information for California residents
Scope. This section applies only to California residents entitled to receive the information in this section under the California Consumer Privacy Act of 2018 (“CCPA“). It describes how we collect, use, and share Personal Information of California residents when we act as a “business” as defined under the CCPA, and their rights with respect to their Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information excluded from the scope of the CCPA. In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.
Your California privacy rights.
As a California resident, you have the rights listed below.
Information. You can request the following information about how we have collected and used your Personal Information:
- The categories of Personal Information that we have collected
- The categories of sources from which we collected Personal Information
- The business or commercial purpose for collecting Personal Information
- The categories of third parties with whom we share Personal Information
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third-party recipient
- Whether we have sold your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient
Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
Deletion. You can request that we delete the Personal Information that we have collected from you.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of any unlawful denial of service, increase in the price of services, decrease in service quality, or suggestion that you may be penalized for exercising your rights.
Possible use of your Personal Information
If you do not want your personal information sold to third parties, please notify us at Support@SHAP.market. Please see below “How to exercise your rights” regarding such notification.
How to exercise your rights
You can request to exercise your information, access, and deletion rights by contacting us at Support@SHAP.market.
We may decline your request where required or permitted by law. We will need to confirm your identity to process your requests and we reserve the right to confirm your California residency as well. Government identification may be required. You may designate an authorized agent to make a request on your behalf by providing a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. You should transmit your government-issued identification or any other sensitive information to us only as instructed. Email is not a secure means of communication and you should not email your government-issued identification or any other sensitive information to us.
Personal information that we collect, use, and share
The chart accessible here provides additional information pursuant to the CCPA about the Personal Information we collect, use, and share.
Information for users in the United Kingdom and Europe
The information in this section applies only to individuals in the United Kingdom and the European Economic Area (“Europe”).
Retention. We retain personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested; to comply with applicable legal, tax, or accounting requirements; to establish or defend legal claims; or for fraud prevention). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
The data protection laws of the United Kingdom and Europe give you certain rights regarding your personal information. If you are located in the United Kingdom or Europe, you may ask us to take the following actions in relation to your personal information that we hold:
Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information.
Transfer. Transfer a machine‐readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information.
Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by email to Privacy@SHAP.market or our postal address, 1151 Walker Rd, PMB 315, Dover, DE 19904 .
We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us at Privacy@SHAP.market or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross‐Border Data Transfer
If we transfer your personal information from Europe to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so, for example, by implementing the standard contractual clauses adopted by the European Commission. Similarly, if we transfer your personal information from the United Kingdom to a country outside of the United Kingdom such that we are required to apply additional safeguards to your personal information under data protection laws of the United Kingdom, we will do so, for example, by implementing the applicable standard contractual clauses. Please contact us at Privacy@SHAP.market for further information about any such transfers or the specific safeguards applied.