Privacy Policy

Scope of policy

This privacy policy covers your use of Shark Famly Investments, INC.’sweb site and related services (the “Different Never Less Site”). This policy applies to online and offline collection, storage, processing and transfer of personal information.

We, meaning Different Never Less Site, endeavor to obtain personal information lawfully and by fair means, and comply with relevant global privacy and data protection laws and regulations.

What information we collect

We collect information from you when you register on our site or fill out a form. Any data we request that is not required will be specified as voluntary or optional. When registering on our site, as appropriate, you may be asked to enter your: name, e-mail address, mailing address or contact information. You may, however, visit our site anonymously.

We may collect certain personal information, including non-personally identifiable information (NPI) and personally identifiable information (PII) that is given to us by you, including your email address. We do not knowingly collect PII from anyone under the age of 13.

The information we may collect in the course of offering our services includes, without limitation:

  • Contact data, such as: IP address, Email addresses, Phone numbers, Text notes, content stored in files, web addresses.
  • Metadata and data for interactions, such as: communication preferences, email addresses or other contact information of persons to notify, email headers that contain Personal Data, Metadata of emails (times sent, etc.) that are linked to Personal Data, Metadata about purchases made from our web store, metadata and structured data about the tags in a user’s account – as chosen by the user.

How we use information

  • Unless you choose to protect your PII through the secure portion of the Site, your PII will be publicly available on the Different Never Less Site.
  • We do not sell, rent, lease, share or transfer the PII we collect.
  • We use PII where permitted by or required by law, for internal record keeping, to enforce our rights, protect our property, comply with legal or regulatory requirements or protect your safety.
  • We provide cloud based smart tag services to you. We process personal data as necessary to perform these services. In addition to storing and retrieving data, we carry out necessary processing to generate reports and insights of your interactions with third parties viewing your tags as set up by you.
  • To personalize your experience (your information helps us to better respond to your individual needs)
  • To improve our website (we continually strive to improve our service based on the information and feedback we receive from you)
  • To improve customer service (your information helps us to more effectively respond to your customer service and support needs)

Do we use cookies?

Yes. Cookies are small files that a site or its service provider transfers to your computers hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information. Different Never Less Site webApps, which are used for purchasing, managing and viewing the tags, require cookies to work properly.

Where do we process data?

We locate our data centers in the United States and by utilizing our services, you expressly instruct us to process personal data within the United States and consent to its processing in accordance with this privacy policy.

Do we disclose any information to outside parties?

We do not sell, trade, or otherwise transfer your personal information except in accordance with this policy. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Your Choices and Rights

  • You may request that your PII be protected through the secure portion of the Different Never Less Site, in which case you will select a secure personal identification number, or PIN, to access your secured PII and your PII will not be publicly available on the Different Never Less Site.
  • Upon request, will make reasonable efforts to correct, change, or remove your personal information on a timely basis. Please be aware that we may not be able to expunge all information from historical log records or when legally required to keep the information.
  • We will address promptly any complaints or disputes regarding your personal information or our privacy policy. We will utilize independent mediation if we cannot resolve privacy concerns directly with a user. We will assist a user in achieving satisfaction if there are privacy issues or concerns.

 

Children’s Privacy

The Different Never Less Site is not intended for use by persons under 13 years of age. We do not knowingly collect or maintain PII or NPI from persons under 13 years of age, and no part of the Different Never Less Site is directed to persons under 13. If we learn that personal information of persons less than 13 years of age has been collected without verified parental consent, we will take reasonable and appropriate steps to delete this information.

Access to Your Data & Accuracy

Accurate data is important and necessary to provide the Different Never Less Site to you. We take steps to ensure that the personal information we collect and process is accurate, complete, and current. Nonetheless, we depend on you to update or correct personal information.

You may access, change or delete your personal information at any time. We will make reasonable efforts to correct, change, or remove your information on a timely basis. Please be aware that we may not be able to expunge information 1) from historical log records or 2) when legally required to keep the information.

Data Security

We make efforts to implement commercially reasonable data security measures on our systems that are designed to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. However, please be aware that no data transmissions over the Internet can be guaranteed to be secure. As a result, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

We encrypt personal information using Secure Sockets Layer (SSL) technology to ensure that your information is safe during transmission over the Internet.

Redress and Enforcement

Different Never Less Site will make every attempt to ensure user satisfaction if there is ever an issue or concern with the Different Never Less Site. You may contact us directly by one of the methods shown in the Contact Us section of this policy if you have a question or concern regarding the privacy or security of your personal information. We will contact you within 30 days with a resolution or answer to your question.

From time to time, we will review our information collection, use, and disclosure practices in order to ensure that we are complying with our privacy policy and applicable laws and regulations. If you have any concerns about the privacy or security of your personal information, please Contact Us.

Data Retention and Data Subject Rights

If you are an EU citizen and you wish to request that we a) identify the personal information we have about you; b) delete the personal information we have about you; or c) exercise any other data subject right you may have under applicable law, please email us at Support@DifferentNeverLess.com and we will work with you to comply with your request as legally required.

Online Privacy Policy Only

This online privacy policy applies only to information collected through our website and not to information collected offline.

EU Residents

“Data controller” and “Data Processor” are important concepts in understanding a company’s responsibilities under the GDPR. Depending on the scenario, a company may be a data controller, data processor or both — and has specific responsibilities as a result:

Data Controller

A company is a data controller when it has the responsibility of deciding why and how (the ‘purposes’ and ‘means’) the personal data is processed.

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§  Under the GDPR, data controllers have to adopt compliance measures to cover how data is collected, what it’s used for and how long it’s retained. They also need to make sure people can access the data about them.

§  Data controllers must ensure data processors meet their contractual commitments to process data safely and legally.

Data Processor

A company is a data processor when it processes personal data on behalf of a data controller. Under the GDPR, data processors have obligations to process data safely and legally.

While Different Never Less Site is a data controller in many aspects, there are instances in which Different Never Less Site is a data processor. For example when end users are loading information into their Smart IDs, they make the decisions as to what the content is, and which security mechanisms provided by Different Never Less Site are engaged. In that case, Different Never Less Site is a data processor for the end user, who is acting as the data controller.

Different Never Less Site ensures that persons authorized to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;

Different Never Less Site will, at the choice of the end user, which can be exercised via the self-service facility or by emailing the choice to privacy@Different Never Less Site.com, delete  all the personal data belonging to the end user.

Changes to our Policy/Acceptance

This privacy policy may be revised by Different Never Less Site in its sole discretion at any time. We will endeavor to distribute any substantive change to our policy 30 days prior to the change taking effect.

We will request your permission if there is a substantive change in the way your personally identifiable information may be used, shared or transferred. Your continued use of the Different Never Less Site after the privacy policy has been revised and distributed will signify your acceptance of such revised terms for information provided by you. We encourage you to review our privacy policy whenever you use the Different Never Less Site to make sure you understand how your information will be collected and used.

If we decide to change our privacy policy, we will post those changes on this page and update the Privacy Policy modification “Last update” date below. Policy changes will apply only to information collected after the date of the change.

Your Consent

By using our site, you consent to our privacy policy. If you do not consent to the collection and processing of the information required to be processed, we are unable to provide you with our service, and you should not use our site.

Definitions

  • Personally Identifiable Information (PII) includes any data that can identify, contact, or locate a specific individual – for example: name, address, email address, and telephone number.
  • Non-Personally Identifiable Information (NPI) includes data that does not by itself identify a specific individual.
  • Aggregate data is generally NPI about individuals that is combined into a total and essentially anonymous.