PRIVACY POLICY AND NOTICE

I. Privacy notice

Controller information:

Who we are? www.sheshaft.com (“The site”)

Contact details with www.sheshaft.com

Manager: Chang Prinston

E-mail: support@sheshaft.com

Internet site: www.sheshaft.com

Contact details with Data Protection Officer (Response person for GDPR):

Name: Chang Prinston

E-mail: support@sheshaft.com

Your personal data that we process are:

Personal data category:

• E-mail
• Names (optional)
• Photos (optional)

We declare that the personal data we collect will only be used for the following purposes upload videos, for password recovery, sites statistics.

The basis that entitles us to process your data is:

• Agreement
• Customer consent

The following organizations / individuals will receive your personal data:

• The third organizations don’t receive your personal data.

Consent:

By agreeing to accept this Privacy Notice, you authorize us to process your personal information only for the purposes we specify.

In cases where we want consensus on special (sensitive) personal data, we will always be motivated why and how this information will be used. You can withdraw your consent at any time

Data storage period:

“The site” will store your personal data no more than 5 years.

Your rights as a data subject are as follows:

At any time while we store or process your personal data, you have the following rights:

• you have the right to request a copy of your personal data of “the site”.
• and the right of access at any time to your personal data;
• you have the right to request your personal data in a form convenient to transfer to another personal data administrator from “The site”, or to ask us to do so without being hindered by ourselves;
• you have the right to ask “the site”
• to correct without undue delay your inaccurate personal data as well as the data that is not up to date;
• you have the right to request from “the site” that your personal data be deleted without undue delay in any of the following circumstances:
  • personal data are no longer needed for the purposes for which they were collected;
  • when you have withdrawn your consent;
  • when you have objected to the processing,
  • when processing is unlawful;
  • where personal data must be erased in order to comply with a legal obligation under EU law or the law of a Member State that applies to us as a data controller;
  • when personal data have been gathered in connection with the provision of information society services.

We may refuse to delete your personal information for the following reasons:

• in the exercise of the right to freedom of expression and the right to information;
• to comply with a legal obligation on our part or to carry out a task in the public interest,
• in the exercise of the official powers granted to us (in case you are a body of authority);
• for reasons of public interest in the field of public health;
• for purposes of archiving in the public interest, for scientific or historical research or for statistical purposes, in so far as deletion is likely to render impossible or seriously obstructing the achievement of the purposes of such processing; or for the establishment, exercise or protection of legal claims.

You have the right to request from “the site” to restrict the processing of your personal data, in which case the data will only be stored but not processed. Our refusal to restrict will be explicit only in writing, and we are obliged to motivate it for the legitimate reason;

• You have the right to withdraw your consent to the processing of your personal data at any time with a separate request addressed to the administrator;
• You have the right to object to certain types of processing, such as direct marketing (unsolicited advertising messages);
• You have the right to object to automated processing, including profiling;
• You have the right not to be the subject of a decision based solely on automated processing including profiling;
• If we need to use your personal data for a new purpose not covered by this data protection statement, we will provide you with a new data protection skill and when and where necessary we will require your prior consent for the new processing.

All the above requests will be forwarded if there is a third party (recipients, including outside the EU and international organizations) in the processing of your personal data.

You have the right to complaint to the supervisory authority

In case you wish to file a complaint about the processing of your personal data through “the site” (recipients, including outside the EU and international organizations), you can do so by contacting “the site” or directly of the Data Protection Officer (the contact details listed above).

You can read more about how and why we use your data here: https://www.sheshaft.com/

II. Privacy policy

I. General provisions and definitions

1. The Privacy policy of “The site” is based on the personal data protection requirements and principles adopted by virtue of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (Regulation (EU) 2016/679 or General Data Protection Regulation).

2. The terms listed below have the meanings assigned to them in the Regulation (EU) 2016/679 (General Data Protection Regulation) and the accompanying Policy:

Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Controller means any natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its

Data subject is an identified or identifiable natural person who can be identified, directly or indirectly, based on particular information representing personal data;

3. “The site” acknowledges the privacy of natural persons and makes efforts to protect them against any unlawful processing of their personal data. “The site” applies the relevant technical and organisational measures to protect the personal data of natural persons in accordance with the effective legislation.

II. Processing of personal data

4. “The site”, in its capacity as controller of personal data, processes personal data in a manner that ensures appropriate level of security, including protection against unauthorised or illegal processing and against accidental loss, destruction or damage, while applying suitable technical and / or organisational measures in compliance with the following principles:

(a) lawfully, fairly and in a transparent manner in relation to the data subject ("lawfulness, fairness and transparency")

(b) data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes ("appropriateness in the processing of personal data and purpose limitation")

(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed ("data minimisation")

(d) accurate and kept up to date

(e) limitation of the storage for periods not longer than necessary for the purposes for which they are processed ("storage limitation")

(e) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures ("integrity and confidentiality").

5. “The site”, processes personal data only if and to the extent at least one of the conditions listed below shall apply:

(a) processing is required for the performance of an agreement with the “The site”, under which the data subject is party or to undertake steps at the request of the data subject prior to the signing of an agreement with “the site”

(b) processing is required for compliance with a legal obligation which applies to the “The site”, in its capacity as controller of personal data.

(c) the data subject has given consent for the processing of their personal data for one or more specific purposes. In the cases when personal data are processed solely on the grounds of consent, the data subject has the right to withdraw such consent at any time. Withdrawal of the consent of the data subject is not applicable in the cases when the processing of the data is based on the provisions of items "a" and "b" above.

6. “The site”, , in its capacity as controller, does not process personal data which reveal racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, and the processing of genetic data, biometric data solely for the purpose of identification of the natural person, data concerning health or data concerning sex life or sex orientation of the natural person unless the data subject have given an explicit consent for the processing of such data for one or more specific purposes.

Rights of the data subjects (customers – natural persons whom the data relates to)

7. Right to information (in relation to the processing of the data subject's personal data by the “The site”, - the natural persons that are data subjects have the right to receive information* as to the “The site”, as personal data controller, as well as the processing of their personal data.

8. Right of access to own personal data - the data subjects have the right to receive from the “The site”, confirmation as to whether personal data related to them are processed and if so, to be given access to the data and the following information: purpose of the processing; respective personal data categories; personal data recipients or categories of recipients, if any; the intention of the controller to transmit personal data to a third party (where applicable); personal data storage period; existence of the right to correct personal data, as well as the right to object against the processing of personal data; existence of automated decision making, including profiling (if any); information as to all rights that the data subject has; the right to file a complaint with the supervision authority.

9. Right to rectification of personal data (if data is not accurate) - the data subject has the right to request the Www.sheshaft.com/ to rectify, without undue delay, any incorrect data pertaining to the data subject.

10. Right to erasure of personal data (right "to be forgotten") - the data subject may request from the “The site”, to erase personal data, if any of the conditions listed below exist:

• Personal data are no longer needed for the purposes they have been collected for or processed otherwise;
• The data subject withdraws his / her consent, which data processing is solely based on, and no other legal grounds for the processing exist (processing due to regulatory obligation of the Www.sheshaft.com/, an agreement signed with the “The site”,
• The data subject objects against the processing and no legal grounds for the processing exist that prevail;
• The personal data were processed unlawfully;
• The personal data should be erased in order to comply with a legal obligation under the European Union law or the laws of the Republic of France, which apply to the “The site”, in its capacity as personal data controller;
• The personal data have been collected in relation to the offering of information society services to children and consent was given by the holder of parental responsibilities for the child.

11. Right to limitation of processing by “The site”, or by the personal data processor - specific conditions are required to be in place for that right to be exercised, namely:

• Accuracy / up to date nature of the data is disputed by the data subject. In this case the limitation of the processing is over a period of time allowing the “The site”, to check the accuracy of the personal data;
• The processing is unlawful, but the data subjects do not wish their personal data to be erased, but rather require limitation of their use;
• “The site”, no longer needs such personal data for processing purposes, but the data subject requires them for establishing, exercising or defending legal claims;
• The data subject has objected to the processing while awaiting a check to be performed whether the “The site” legal grounds prevail over the interests of the data subject.

12. Right to transferability (data portability) of the personal data between the various controllers - the data subjects have the right to receive personal data pertaining to them, which they have provided to the “The site”, in a structured, widely used and machine readable format and have the right to transfer such data to another controller without hindrance by the “The site”, , to which personal data has been provided, when processing is based on consent or contractual obligation and the processing is automated. When exercising the right to transferability the data subject has the right to receive also direct transfer of the personal data from the “The site”, to another controller, where technically feasible.

13. Right to object against the processing of their personal data - data subjects have the right to object before the “The site”, against the processing of their personal data, whereby the “The site”, shall cease such processing, unless “The site”, is able to prove that compelling legitimate grounds for the processing exist that override the interests, rights and freedoms of the data subject, or for the establishment, exercising or defence of legal claims. In case of objection against the processing of personal data for direct marketing purposes the “The site”, shall cease such processing forthwith.

14. The data subject also has the right not to be subject to decision based solely on automated processing, including profiling, which ensues legal consequences for the data subject or significantly affects the data subject otherwise.

15. Right to defence through judicial or administrative procedure if the data subject's rights have been breached - if the data subjects decide that their right to personal data protection and privacy has been violated, they may file a complaint with the relevant supervision authority - or to file a claim with the court to defend their rights.

III. Disclosure of personal data

16. “The site”, may disclose the personal data to the following categories of persons:

• The persons whom the data relate to, namely: persons using “The site”, services or products, or persons filing a request to use “The site”, services, as well as persons who are party to “The site”, and / or other transactions and contractual relations with the “The site”, /;
• Persons that have right to access to personal data by virtue of law or another regulation;
• Persons as to whom the right to disclosure is stipulated in an agreement signed with the “The site”,

V. Exercise the rights

17. (1) In exercising their right to access natural persons have the right to request from “The site”, at any time:

1. Confirmation as to whether data related to them are processed by the “The site”, ,the purpose of the processing, the data category and recipients of such data or the categories of recipients’ data is disclosed to;
2. To send them a message in an understandable format, containing the personal data subject to processing and any information available as to the source of such data;
3. Information as to the logic of any automated processing of personal data pertaining to natural persons, at least in the case of automated decisions under the provisions of the General Data Protection Regulation

(2) Upon request “The site”, provides the information under paragraph 1 free of charge.

(3) Natural persons have the right to request at any time that “The site”,

1. erases, rectifies or blocks their personal data the processing of which is not compliant with the requirements of the effective legislation
2. notifies the third parties to which the personal data of the natural persons have been disclosed as to any erasure, rectification or blocking in accordance with item 1 above, except when this proves to be impossible or would involve a disproportionate effort.

18. (1) Natural persons exercise their rights by filing a written request to the “The site”, , containing as a minimum the following information:

1. name, personal ID number, address and other data allowing identification of the respective natural person;
2. description of the request;
3. Signature, date, correspondence address and telephone number.

(2) The filing of the request is free of charge.

(3) Upon filing of a request by an authorised person, the notarised power of attorney must be attached to the request.

(4) In case of death of the natural person, his / her rights are exercised by his / her heirs and certificate of heirs shall be attached to the request.

19. “The site”, shall review and pronounce on the request within 1 month as of its filing. This period may be extended by further two months, if necessary. The “The site”, informs the data subject as to any such extension within 1 month as of receipt of the request, stating the reasons for the delay. When the data subject files a request by electronic means, the information is provided electronically, if possible, unless the data subject has requested otherwise.

20. “The site”, provides an answer to the requesting person taking into account their preferred form for the provision of the information (orally or in writing - as a hard copy of electronically).

21. Where data do not exist or their provision is forbidden by law, access of the requesting party to such data is refused.

22. If the requesting party is not satisfied with the response received and / or believes that their rights related to personal data protection were violated, they are entitled to exercise their right to defence.