Our commitment

Your privacy and the security of your personal data is one of our highest priorities. We take our information security responsibilities very seriously and are committed to protecting the privacy of your personal data.

We want to be as clear and open as possible about what we do with the information you provide when using the Shooglebox service (“Service”).

Shooglebox is managed by IMP Media Limited (“we”, “us” “our”) whose registered office is at 7 Park Row, Leeds, LS1 5HD, United Kingdom. Our registered number is 5958961.

We comply with Data Protection laws in the United Kingdom and the EU General Data Protection Regulation (GDPR). Our ICO register number is Z9868126.

If you wish to contact us about Shooglebox or have any other question, please contact us at info@shooglebox.com.

In this Privacy Policy we use the same terms as specified in the Terms.

What information do we collect?

Shooglebox is a creativity tool that lets you upload, store, create and explore your notes, sound recordings, photos, videos, web links and other information and material (Your Content).

We also collect and receive the following types of information:

Basic user profile information: When you create a Shooglebox account we collect your name, email address, a profile photo and confirmation that you are aged 16 or over.
Billing details: If you set up and subscribe to a Paid Account we collect your name, billing address and payment information.
Usage data: We collect and log information about how you and others access and use the Service – e.g. numbers of cards or boxes created, boxes shared, access times, number of sessions. This data is collected through cookies and other technologies.
IP address: We collect the IP address you use to access the Service and the location information associated with that address.
Device information: We collect information about the type of devices you use to connect to the Service and information about their operating systems or browsers.

How do we use the information we collect?

We use the information we collect to provide, manage and improve the service; to contact you when necessary, and to give help and support.

This covers:

Registering your Shooglebox account and creating a profile on the Service.
Ensuring an optimal best experience based on device, screen size etc.
Providing guided help, recommendations, and suggested actions to help you get the best out of Shooglebox based on your use of the Service.
Providing technical support and to help with the diagnosis of issues.
Providing billing advice and reminders.
Sending service messages about important updates and invitations from other users within the Service.
Sending you emails about service features or tips on getting the best out of your Shooglebox account. You can change your communication preferences at any time. We don’t want to send you messages you don’t want to receive.

Who can access Your Content?

We have specific rules around how we handle the Your Content.

You have control over who can see Your Content. By default only you can see Your Content – but you have the option to share one or more box of cards with other Service users. You must ensure you have the right to share any content and that it does not infringe the rights of others – including privacy and intellectual property rights.
If you are part of a Team account, the Administrator determines which users are added to the Team account – but they cannot access your personal account and boxes.
We may ask temporary permission to see specific pieces of Your Content to help investigate or diagnose an issue – or to help understand a particular use case or user request. Choosing to give permission is up to you. This permission terminates when your issue or request is resolved.
If we are alerted to a potential violation of our Terms, we may suspend or close your account pending investigation and resolution. We will only look at Your Content to investigate or comply with specific legal, security or safeguarding obligations.

Who is your data shared with?

We will not sell or share your data with others for the purpose of advertising or marketing other services. There are several instances where we need to disclose your information in order to provide the Service:

Information is shared with trusted service providers who process data and provide services to us, such as internet hosting and the processing of payment details.
Information provided in respect Team accounts may be shared with the Administrator.
If you use the Shooglebox Share by email feature to send someone a link to a shareable read-only box, your registered name and email address will be visible to the person who receives the email.
Third party service providers must adhere to strict data protection guidelines in keeping with our privacy policy, GDPR, and Standard Contractual Clauses (SCCs).

Marketing information

Shooglebox marketing information will only be sent to you if you have opted in to receive marketing communications.
You can opt out of receiving further communications at any time.

How is your information protected?

We use robust security measures, including physical, operational, and technical safeguards to protect the confidentiality of your data. These include encryption, access controls, information security policies, procedures and other information security measures which are designed to help protect your Information.
Wherever possible, we also try to anonymise information so that individuals cannot be identified from it.

How do we use cookies?

Cookies are small data files that are stored by your browser when you visit a web site. Each website stores its own cookies and cannot read the content of cookies from another website.

We use our own cookies, as well as third-party cookies and similar technologies to assist with the providing core functionality, security, reporting and analysis such as:

Logging in and keeping users logged in to the Service
Remembering user preferences
Understanding how people are using the Service

We may also include tracking pixels in our email messages to determine whether an email was opened and which links were clicked.

When you link to external web sites and services from Shooglebox e.g. Facebook, Twitter or YouTube, these services may store their own cookies on your browser too. We have no control over these cookies or how they are used by the third party service.

The types of cookies and similar technologies we use are:

Essential – required for providing core features of the site such as logging in and session management.

Analytics – providing anonymised information about usage, devices and site performance.

Functional – recognising when users are signed in the Service and providing features and preferences based on a user’s choices.

You can change your browser settings to not accept cookies, but this may limit your ability to access all or some parts of the Service. Please consult the help and support section of your browser for more information about how to disable cookies.

How and where is your information stored?

Information is cloud hosted securely using replicated databases designed to maximise security, performance, and availability.
Wherever your information is held and processed, it is protected to the same high standard as required by law in the United Kingdom.
The transmission of Shooglebox data is encrypted using secure socket layer technology (SSL/TLS) by default and also encrypted at rest.
We and our service providers and hosting partners are certified to the ISO27001 standard.
To provide you with the Service, we may store, process and transfer information at different locations around the world, including outside your country of residence.
When transferring data from the European Union, the European Economic Area and Switzerland, we rely on a variety of legal mechanisms, including contracts, model contact clauses, regulatory compliance and data transfer agreements with our suppliers and partners. Each vendor goes through a rigorous selection process to ensure it has the necessary technical expertise to deliver an appropriate level of compliance, privacy and security.

How long is your information retained?

When you sign up for a Shooglebox account, we will retain your information for as long as your account exists or as long as we need it to provide the Service.
If you delete your account, we will delete all of Your Content within 30 days, and all other information associated with your account – including your name and email address – within 12 months.
We may delete your account, Your Content and other data if the account has not been accessed for two years unless it is a Paid Account. We will contact you by email prior to deleting – and give you the opportunity to keep your account or time to download Your Content before the account is closed.

How do you manage or delete your information on Shooglebox?

Your Content and data belongs you and you can manage it by logging in to the Service and editing or deleting your information.

You are in complete control of creating, managing and deleting Your Content, personal information and account.
If you delete a box of cards you have shared with other Shooglebox users, the box and the cards will no longer be accessible to you or others. But please remember that if you decide to share a box of cards, other users may be able to copy a card or number of cards.
If you are using a Team account, your Administrator may have asked you to agree to additional obligations specific to your organisation.

How do we respond to legal requests?

We will only disclose information if required to comply with warrants, court orders, or other legal requests.
In some cases, we may need to share your information to investigate or comply with a specific security, legal or safeguarding obligation.

How do we comply with EU data transfer regulations?

You have the right to access information we hold about you and to request that we correct, update or delete it.
You can request a copy of the personal information we hold about you by writing to us at the address shown below.
You are permitted to copy and download personal information that we hold about if you ever need to use your personal information outside of the Service.

Changes to the Privacy Policy

We may revise this Privacy Policy from time to time. The current version can be found on the Shooglebox website.
If we make a significant change to the policy, we will inform you by email.
If we are involved in a reorganisation, acquisition, sale or merger, your information may be transferred as part of that deal. We will inform you in the event that this takes place.

Contact

If you have any questions or concerns about Shooglebox, our policies or privacy, or if you wish to exercise any of your rights regarding your personal data, please contact us at privacy@shooglebox.com.

We shall respond to your request as soon as possible, depending on the complexity of the request but no later than one month from receiving it.

If you are not satisfied with how we respond to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.

Policy last updated: 14th November 2022