Privacy Policy


Introduction

The privacy of our customers and users is very important to us, and we are committed to safeguarding it. This privacy policy describes the collection, use, and disclosure of user information by Shrinkage, its employees and agents, and its affiliates (“us” or “we”) in connection with the operation of the Shrinkage mobile application, and our related Apps and hosted software platforms (collectively the “App”). This policy applies to national and international versions of the App.


About Us

Shrinkage processes Personal Data both as a Processor and as a Controller, as defined by the European Union’s General Data Protection Regulation (GDPR). For more information about our Privacy Policy or how your information is used, please contact us at support@shrinkageinc.com.

Our Data Protection Officer (DPO) can be contacted at support@shrinkageinc.com for additional information about Shrinkage’s policy for using and storing information and data.


Collecting Information

By using the App, you are consenting to allow Shrinkage to collect, store, and use the following information:

  1. Information You Give Us: We collect personally identifiable information such as customer names, email address,‎ phone numbers, physical addresses, username,‎ password,‎ demographic information (such as your gender and occupation), entity information, payment information, and other information you directly give us on our App.
  2. Information We Get from Others: We may collect information gathered from third-party sites or sources you accessed, such as Facebook, Google, or Twitter. We may add third-party retrieved information to the information collected from you on our App. Some third-party sites or sources may also provide us with information from your accounts to enhance and personalize your use of our App. Third-party sites may also include Alcohol Vendors and Wholesalers. You have the right to modify your privacy settings and opt-out of providing certain information or receiving interest-based advertisements on those third-party sites our sources directly on their respective site.
  3. Passive Information Collected: We do automatically collect usage data and computer operating information such as the operating system type, cookies, web beacons, browser type,‎ browser language,‎ the App you visited before browsing to our App,‎ pages you viewed,‎ how long you spent on a page,‎ access times,‎ Internet protocol (IP) address, and other information about your use of and actions on our App to customize your visit through technical means. We also collect information that is entered into the App through App devices and mechanisms such as liquid levels, inventory quantities, point of sale metrics, historical data ordering and receiving reports, and payment information.
  4. Public Content: You can contribute to the App in several different ways, including uploading photos, embedding videos, participating in forums, tagging products, filling out your profile. We may store these contributions (your “Public Content”), display them to other users, and use them for promotional purposes. Note that if you include personally identifiable information in your Public Content, it can be used and viewed by others. We are not responsible for the information you choose to include in your Public Content.

You many not disclose to us the personally identifiable information of another person, without first obtaining that person’s express consent to both the disclosure and the processing of that personally identifiable information in accordance with this policy. Any personally identifiable information that contains financial or sensitive information will not be disclosed by Shrinkage to any third-party, or otherwise be disseminated to the public.


Using Information Collected

Information submitted to us through our App will be used for the purposes specified in this policy or as provided for on the relative App page. Your personally identifiable information may be used for one or all of the following reasons:

  1. To operate, maintain, and improve our sites, products, and services;
  2. To calculate and measure operational metrics;
  3. To send information including confirmations, technical notices, updates, security alerts, and support and administrative messages; and
  4. To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.

Any personally identifiable information submitted by you for publication on our App grants us a license to use your personally identifiable information.

You may modify your privacy settings to limit our use of your information on the App by adjusting the App privacy controls.

We will not, without your express consent, supply your personally identifiable information to any third party for their or any other third party’s direct marketing.


Sharing Your Information

We may share or sell your personally identifiable information as follows:
  1. We may share personally identifiable information to third parties with your express consent, including sharing personally identifiable information or other information collected through your use of the App for third-party marketing uses subject to their third-party privacy policies and third-party sales analytics.
  2. If you post Public Content on the App, we may distribute such Public Content to a wider audience by sharing it (or portions of it) with third parties so that they can publish it on their own Apps and media platforms. We allow you to access third party services, such as Facebook, Google, and Twitter, to share your selected Public Content with those services.

We expressly reserve the right to release any personally identifiable information or other information you provide to third parties: (a) when required by law or legal process, (b) to investigate and/or take action against illegal activity, suspected abuse, or unauthorized use of our services, (c) to protect the property or safety of our users or others, (d) to enforce our Terms of Use, and (e) in connection with any sale or other transfer of ownership of all or a part of Shrinkage, or any of its affiliates.

If you make any personally identifiable information publicly available on the App (e.g., by posting a listing which contains personally identifiable information), anyone may see and use such information and we are not responsible for such use. The App reserves the right to share any personally identifiable information you post on the App with third parties with your prior consent. To the extent the App does so, the subsequent use and disclosure of such information is subject to the privacy policies and practices of those third parties.


Disclosing Your Personally Identifiable Information

We may disclose your personally identifiable information to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy and our Terms and Conditions.

We may disclose your personally identifiable information to any member of our companies (including any of our subsidiaries, holding companies and all its subsidiaries) as reasonably necessary for the purposes set out in this policy and our Terms and Conditions.


International Data Transfers

The App is hosted in the United States, and all or a portion of the App may also be hosted on the “cloud”, or other similar distributed hosting platform. If you are accessing the App from the European Union, Asia, or any other region with laws governing personal data collection, use, and disclosure that differ from United States laws, please note that you are transferring your personal data to a jurisdiction that does not have the same data protection laws as your home jurisdiction. By providing your personal data you consent to:

  1. our use of your personal data for the uses identified in this Privacy Policy, and
  2. the transfer of your personal data to the United States.

Under the General Data Protection Regulation (GDPR), if you have provided consent for the processing of your personal information, you have the right to withdraw consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn. You have the right to request access to and rectification or erasure of your personal information, as well as the right to restrict processing, object to processing, and under certain circumstances the right to data portability.

The following are your fundamental rights granted to users under GDPR:

  1. The right to be informed – Shrinkage will be completely transparent in how we are using your personal data, please refer to Section D above.
  2. The right of access – Users of Shrinkage have the right to know exactly what information is held about them and how it is processed.
  3. The right of rectification – Users of Shrinkage will be entitled to have personal data rectified if it is inaccurate or incomplete.
  4. The right to erasure – This right affords users of Shrinkage the ability to having their personal data deleted or removed without the need for a specific reason as to why they wish to discontinue.
  5. The right to restrict processing – Users of Shrinkage have the right to block or suppress processing of their personal data.
  6. The right to data portability – Users of Shrinkage have the right to retain and reuse their personal data for their own purpose.
  7. The right to object – in certain circumstances, users of Shrinkage are entitled to object to their personal data being used.
  8. Rights of automated decision making and profiling – The right for users of Shrinkage to choose not to be the subject of a decision where the consequence has a legal bearing on them or is based on automated processing.


California Residents:

If you are a California resident, California Civil Code Section 1798.83 permits you to request free of charge information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to support@shrinkageinc.com. Shrinkage does not share personally identifiable information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personally identifiable information to third parties for their direct marketing purposes by withholding consent.


Utah Residents:

WE MAY CHOOSE TO DISCLOSE NONPUBLIC PERSONAL INFORMATION ABOUT YOU, THE USER, TO A THIRD PARTY FOR COMPENSATION. YOU MAY CHOOSE TO OPT-OUT OF SUCH DISCLOSURE TO THIRD PARTIES BY SENDING A WRITTEN REQUEST TO SUPPORT@SHRINKAGEINC.COM


Retaining Personally identifiable information

Our data retention policies and procedures are designed to ensure that we comply with our legal obligations regarding the retention and deletion of personally identifiable information in accordance with all state and federal laws and regulations.

Information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

Shrinkage will keep data for a period of up to 5 years. Users may request Shrinkage to delete their data or request an accounting of all personal data of theirs kept by Shrinkage by sending an email to Shrinkage at support@shrinkageinc.com. Users may also unsubscribe from the App or uninstall the App to remove their information from the database.

Notwithstanding the other provisions of this Section, we will retain documents (including electronic documents) containing personal data:

  1. To the extent that we are required to do so by law;
  2. If we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
  3. To establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

Security Measures

We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personally identifiable information. All personally identifiable information provided to us will be kept on our secure through our web service providers.

You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You are responsible for keeping the password you use for accessing our App confidential; we will not ask you for your password (except when you log in to our App).

If a data breach occurs: If our DPO determines that Personal Identifiable Information has been accessed without authorization, Shrinkage will report any confirmed or suspected situation to necessary parties immediately upon discovery, both orally and in writing, within 72 hours. If Shrinkage reasonably believes a breach has or may have occurred, Shrinkage will release a report to all users identifying:

  1. The nature of the unauthorized access, use, or disclosure;
  2. The nonpublic information accessed, used or disclosed;
  3. The person(s) who accessed, used, disclosed, and/or received nonpublic information (if known);
  4. What Shrinkage has done or will do to mitigate any deleterious effect of the unauthorized access, use, or disclosure; and
  5. What corrective action Shrinkage has taken or will take to prevent future unauthorized access, use, or disclosure.

In the event of a suspected breach, Shrinkage will keep users informed regularly of the progress of its investigation until the uncertainty is resolved. To the extent possible, our DPO will also facilitate the process to warn the victims of the theft so that they can protect their credit and identity


Amendments

We reserve the right to update this policy from time to time. We may also update this policy by publishing a new version on our App. You should check this page occasionally to ensure you understand any changes to this policy. We may notify you of changes to this policy by email or through the private messaging system on our App.


Third-Party Services

Our App may contain links to third-party Apps or services, such as third-party integrations, co-branded services, or third party-branded services (“Third-Party Services”). Shrinkage doesn’t own or control these Third-Party Services. Through your interaction with such Third-Party Services you may be providing information directly to the Third-Party Service, Shrinkage, or both. These Third-Party Services are required to have their own privacy and data collection policies. We encourage you to review those privacy policies before accepting.

While we encourage our business partners to adopt privacy policies and practices that build users’ trust and confidence in the Internet, we are not responsible for the privacy policies or practices of third parties or any of the content of web sites linked to the App or any third-party products or services offered through the App.


Updating Information

If any personally identifiable information or customer input that we hold about you needs to be corrected or updated inform us immediately by sending an email to support@shrinkageinc.com.


Cookies

This App uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but information that we store about you may be linked to the information stored in and obtained from cookies such as user experience, user history, and user inputs.

Most browsers allow you to refuse to accept, block, or delete cookies. Blocking all cookies will have a negative impact upon the usability of many Apps. If you block or delete cookies, you may not be able to use all the features on our App and may experience other technical deficiencies.

Last Updated: July 9, 2019