REVISED MAY 25, 2018
CinchShare is a scheduling and marketing tool built for direct sellers, MLM marketers, solo entrepreneurs and others who wish to manage their social accounts. It integrates with Facebook and other social networking sites and it enables its CinchShare users to create, organize, save and schedule content (the “Services”) from mobile, tablet, laptop and desktop devices.
PERSONAL INFORMATION WE COLLECT
Personal Information means any information relating to an identified or identifiable natural person, directly or indirectly, by reference to a name, identification number, location data, online identifier, or other factors. We obtain Personal Information relating to you from Facebook and from you, upon your registration and when you request support in connection with your use of the Services. CinchShare does not have access to and does not collect Personal Information from third parties with whom you may communicate.
You must log in to your Facebook account in order to register for an account with CinchShare. CinchShare has developed a software app that has been approved by Facebook to permit Facebook users to access the Services. Upon registration, CinchShare will collect the information on your application form. It will also collect certain information from your Facebook account, such as the name you have provided for your Facebook profile, your profile image, your email address, and the time zone. Facebook may limit, from time to time, the Personal Information from your Facebook profile that is available to CinchShare. We do not release your information to third parties except as necessary and appropriate for us to set up your account and process your transaction.
HOW WE USE THE PERSONAL INFORMATION YOU PROVIDE
CinchShare uses the Personal Information that is collected from your application and from your Facebook profile solely to provide you with the Services. We may use your Personal Information to answer your inquiries, enhance your experience with our Services, manage your account, and provide you with support when necessary, including the troubleshooting of any problems with your account. Your support requests can generate additional information such as the browser you use and your device’s operating system. CinchShare maintains records of the support it provides to improve its system and to respond to general issues. We do not release your Personal Information except as required to process your transaction. We do not disclose your Personal Information to third parties for the purpose of directly marketing their goods or services to you.
Also, CinchShare cooperates with government and law enforcement officials or private parties to enforce and comply with law and regulation. We may disclose Personal Information to government or law enforcement officials, or to private parties, that we, in our sole discretion, believe necessary or appropriate to comply with applicable law or regulation, to protect the property and rights of CinchShare, other users or third parties, to assist in the safety of the public or an individual person, or to assist in the prevention of any illegal, unethical, or legally actionable activity, including situations that involve the abuse of our Services.
In addition, you may authorize CinchShare to access your accounts with certain additional social networking sites such as Instagram or Twitter. If you choose to access these accounts, the designated social networking site will provide CinchShare with its platform identification number for your profile, your profile name, and profile image.
LINKS TO THIRD PARTY SITES
CinchShare is committed to protecting the Personal Information it receives. However, no method of transmission over the internet is 100% secure. As a result, we cannot guarantee the security of your Personal Information. However, we use a combination of online and offline security technologies, procedures and measures to help safeguard Personal Information against accidental loss, unauthorized access, destruction, damage, theft or disclosure.
We maintain physical, electronic and procedural safeguards to guard the Personal Information you provide to CinchShare. We use data encryption technology when data is transmitted over the internet to our site. We have implemented an additional layer of encryption, and we both password protect and limit access to all Personal Information.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
The primary purpose of the Service is to assist you in the creation and origination of your social media content and that content is saved while you maintain an account with CinchShare. You may also elect to share specific content that you create with other CinchShare users. You select the audience with whom you share, and you are solely responsible for your posts. In the event you share content with others, your profile image and name will be displayed. CinchShare has no control over information actually posted or shared on Facebook or other social networking site. CinchShare does not provide any third party with access to or otherwise release your content. We do not maintain, or receive information as a result of your post, such as information that may identify the recipient or recipients of your post.
You may delete your content at any time following the instructions on the CinchShare site. You may also cancel your account at any time. Once cancelled, the Personal Information we maintain and any other data will be wiped clean. The sole exception is information related to prior billing history maintained by CinchShare’s affiliated merchant service provider.
CinchShare uses tracking technologies such as cookies, scripts and tags to collect and store information when you visit our site or use our Services. Cookies are small text files placed on the web browser of your computers, smart phones, tablets, and other mobile devices. They are automatically accepted and remain in your browser unless you delete them or change your browser settings to require notification each time a cookie is placed. Cookies are essential to the services we provide, and they are used to remember user preferences. Cookies are also used to analyze trends. By storing information from your visit to our site, such as log-in information, cookies can speed up and improve your experience with our Services.
We also use scripts to allow Google Analytics to collect and portray in graph form, information about traffic to our sites and how you and others use our Services. The information gathered does not identify any individual visitor. The information is aggregated and is anonymous.
CinchShare understands that children require particular protection because they are less aware of the risks involved with the collecting and processing of Personal Information. Since the safety and privacy of children is important to CinchShare, our Services may be used only by individuals over the age of thirteen in the United States. This age requirement is consistent with the Children’s Online Privacy Protection Act of 1998 (COPPA). The primary goal of COPPA is to place parents in control over what information is collected from their young children online. We do not knowingly collect Personal Information from children under thirteen.
Some countries in the European Union and elsewhere require a minimum age of fourteen or greater. In this event, you must be over the minimum age of consent where you live. To obtain this information, you must contact an appropriate website or qualified and knowledgeable adult where you reside.
Children who are under the minimum age must have consent from a parent or other adult having parental responsibility. A parent or guardian who becomes aware that his or her child under the minimum age has provided us with Personal Information without prior verifiable parental consent should contact us at email@example.com. Upon receipt of this written notice, we will promptly delete any Personal Information from our databases and prevent further access to CinchShare Services.
GENERAL DATA PROTECTION REGULATION
The General Data Protection Regulation (“GDPR”) is a comprehensive update to existing European Union privacy laws and is effective as of May 25, 2018. The GDPR applies to companies in the United States and elsewhere that process Personal Information for customers in the European Union. It requires that privacy information be written in clear and plain language and, also, be concise, transparent and easily accessible.
The data protection regulation also requires a lawful basis for the collecting, storage, use and disclosure of Personal Information. Our lawful basis for processing Personal Information includes:
- Consent – Collecting Personal Information with your consent.
- Contractual Necessity – Performing the contract we have with you in connection with the Services.
- Legal – We may be required by law or regulation to collect your data.
- Legitimate Interests – We may have a good and fair reason to use your data in ways which do not hurt your interests and rights. We may also send you promotional communications about our services.
CinchShare processes Personal Information both as a processor and a controller as defined in the GDPR. You may contact the Controller by email at firstname.lastname@example.org.
DATA PROTECTION OFFICER
CinchShare has appointed a Data Protection Officer to coordinate regulatory, contract and legal matters. You may contact our Data Protection Officer by email at email@example.com, or write to us at the following address:
Data Protection Officer
3210 N. Wickham Rd., Unit 2
Melbourne, FL 32935 USA
Attention: Data Privacy Manager
3210 N. Wickham Rd., Unit 2
Melbourne, FL 32935 USA