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Security Policy

United States Privacy Policy
Effective Date: April 1, 2023
Shirofune is committed to protecting the privacy and security of the information we collect and to being transparent about the ways in which we collect and process your information. This statement (the “Privacy Policy”) sets forth our policies and practices for handling the information we collect from you. It applies to the websites and online services that we operate and that link to this Privacy Policy (the “Services”).

I. COLLECTION OF INFORMATION

We collect the following categories of information when you use our Services:
• Information you provide directly to us.
○ Contact Information, including name, email address, telephone or mobile phone number, and address;
o Sign-In Information, including username, password, and account name;
o Profile Information, including, for example, the business/employer you are working on behalf of when using the Services.
o Commercial information, including records of products or services purchased;
o Transaction and Billing Data, including bank account and payment card details, billing address, and transaction history; and
o Correspondence you send to us.
• Information we collect automatically. We collect internet, electronic activity, and other information automatically from the devices and browsers that you use, including your device type; Internet protocol (IP) address; device and advertising identifiers; time zone setting and location; browser type and version; browser plug in types and versions; operating system and platform; Internet service provider; pages that you visit before and after using the Services, browsing history, and search history; the date and time of your visit; information about the links you click, pages you view, and advertising you interact with within the Services and other information about how you use the Services; the technology on the devices you use to access these Services; and standard server log information. If you or your device experiences an error, we collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred.
Without this information, we are not able to provide you with all the requested services, and any differences in services are related to your information.
We may aggregate or de-identify the information described above or otherwise receive aggregate or de-identified information from third parties. Aggregated or de-identified data is not subject to this Privacy Policy.

II. USE OF INFORMATION AND PURPOSE OF DATA PROCESSING

We are committed to maintaining your trust, and we want you to understand how we use the information we collect and when and with whom we may share that information.
Shirofune uses the information it collects about you in a variety of ways, including:
● To provide you with the Services. We may use your information to process your payments, open and maintain user accounts, facilitate the functionality of our Services, and customize the Services.
● To send you electronic correspondence. We may send you emails or otherwise correspond with you to communicate about your use of the Services and your purchases, or to respond to any customer service inquiries or requests for information.
● To improve our Services. We may use your information to maintain, improve, and administer our Services, including through troubleshooting, data analytics, and testing.
● To deliver and measure advertising. We may use your information to deliver more relevant advertising to you off the Services and to measure the effectiveness of those advertisements.
● To keep our Services and users safe. This includes to detect, prevent, and respond to fraud, abuse, security risks, or technical issues.
● To comply with applicable laws and regulations. This includes using your information if needed to protect or exercise our legal rights or defend against legal claims.

III. DISCLOSURE OF INFORMATION

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect. Shirofune may share your information in the following circumstances:
● Authorized third-party vendors and service providers.
o We share your information with third-party vendors and service providers that provide services to us for a variety of business purposes, such as billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing.
• Corporate affiliates. We may share your information with our corporate affiliates.
• Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of bankruptcy.
• Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of Shirofune, our affiliates, users, or the public.
• With your consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.
If you access third-party services through the Services, these third-party services may be able to collect information about you, including information about your activity on the Services, in accordance with their own privacy policies.
If you choose to engage in public activities on the Services, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing information while participating in these areas. We are not responsible for the information you choose to submit in these public areas.

IV. ADVERTISING, COOKIES AND SIMILAR TECHNOLOGIES

When you use our Services, we and our third party advertising partners (including advertising networks and exchanges, data analytics providers, and social networks) use cookies, pixel tags, and other similar technologies (collectively, “cookies”) to collect information from your browser or device. By using the Services, you consent to our use of cookies and similar technologies.
The following types of cookies are used on our Services:
• Essential cookies – These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. These cookies also help keep our Services safe and secure.
• Preference cookies – These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, our Services may not be able to remember certain choices you've previously made (such as a saved country / language preference). These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
• Performance cookies – These cookies collect information about how you use our Services such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.
• Content / advertising cookies – These cookies gather information about your use of our Services so we may improve your experience and provide you with more relevant content and advertising on elsewhere online and across your devices. They remember that you've visited our Services and help us understand usage of our Services. Some of these cookies are from third parties that collect information about your use of our Services in order to provide advertising based on your online activities on our Services and elsewhere online, across your different devices. We do not control the privacy practices of these third parties, and their practices are not covered by this Privacy Policy.
You may be able to refuse or disable cookies by adjusting your web browser settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you and any differences in service are related to the data.
Some of our third-party partners are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here. For additional information on how Google processes your information and what choices you may have, visit their site here. Due to differences between websites and mobile apps, you may need to take additional steps to opt out of interest based advertising for mobile applications. Please check your device settings and mobile app permissions for additional information on how to opt out. You also may stop further data collection from a mobile application by removing it from your mobile device.
Do-Not-Track Signals and Similar Mechanisms. Some mobile and web browsers transmit "do-not-track" signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

V. YOUR RIGHTS AND CHOICES

Depending on the jurisdiction in which you live, you may have the right to request (i) access to your personal information in a portable format, or other information about our data processing practices; (ii) deletion of the personal information we have collected from you; or (iii) correction of the personal information we have collected about you.
Requests should be submitted in writing as set out below. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. You may also be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise your rights and choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Service may change or no longer be available to you.

VI. INTERNATIONAL TRANSFERS

By using the Services and providing us with information, you understand and agree that we may transfer and store your information on servers located outside of the United States.

VII. CHILDREN

The Services are not directed to children under 13. We do not knowingly collect any information from children under 13 through the Services.

VIII. DATA RETENTION, SECURITY, AND INTEGRITY

Information will be retained only for so long as reasonably necessary for the purposes set out above and consistent with our retention policies, in accordance with applicable laws. Among the criteria that impact retention include the duration of our relationship with you, legal and/or compliance obligations such as record retention requirements under law, and litigation or regulatory investigations.
We maintain reasonable security measures to safeguard information from loss, theft interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

IX. CHANGES TO THE PRIVACY POLICY

We may modify this Privacy Policy from time to time. When we update the Privacy Policy, we will revise the “Effective Date” date above and post the new Privacy Policy. We recommend that you review the Privacy Policy each time you visit the Services to stay informed of our privacy practices.

X. CONTACT INFORMATION

If you have any questions about this Privacy Policy or our practices, please contact us via email at partners@shirofune.us or by postal mail at: 222 Pacific Coast Hwy, El Segundo, CA 90245.

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