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Shift Digital California Privacy Notice

Last Updated: January 1, 2023

Here at Sanctus LLC, d/b/a Shift Digital (“we,” “us,” “our”), we work hard to build and maintain a relationship of trust with you. This California Privacy Notice (the “Privacy Notice”) provides California consumers with certain information about our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) (“Site”), such as www.shiftdigital.com, and any services, transactions, or other engagements you might have with us including use of any applications we provide (collectively, the services we perform are referred to as “Services”). You should review our Privacy Policy for additional information. This Privacy Notice is not applicable to individuals residing outside the State of California.

This Privacy Notice does not describe our privacy practices with regard to data we process on behalf of companies for whom we perform work (“Clients”). It also does not describe our privacy practices with regard to information about job applicants, employees, beneficiaries, or contractors.


INFORMATION WE COLLECT

Personal Information

We may collect, use, and disclose information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”). The specific categories of Personal Information collected and how that Personal Information is used or disclosed may vary based on your relationship with us. Within the past twelve months, we have collected the following categories of Personal Information:

Personal Information Category
Examples
Do we collect this information?
Identifiers
A real name, alias, mailing address, billing address, phone number, IP address, email address, account name, device ID, or other similar identifiers.

YES
Personal Information listed in Cal. Civ Code1798.80(e)
Name, signature, address, telephone number, and credit/debit card number, brand, expiration date. Shift Digital does not collect personal information in this category beyond the personal information it collects in other categories identified herein.

YES
Protected classification characteristics underCalifornia or federal law
Age, race, ethnicity, gender, marital status.

NO
Commercial information
Transaction history, interest in our goods or services, records of communications with us, Sites or Services login history, payment information.

YES
Internet or other electronic network activity
Browsing/search history, browser type, location of browser request, interaction with online advertisement, in-app notifications and settings.

YES
Geolocation data
Physical location or movements.

NO
Audio, electronic, visual, thermal, olfactory, or similar information (“sensory information”)

Call recordings, video or audio surveillance records.
YES
Inferences drawn from other personal information
Profile relating to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES


The Personal Information collected, used, and disclosed on our Clients’ behalf is governed by their privacy policies.

Sensitive Personal Information

We do not collect “sensitive personal information” about you as defined under California law.


PURPOSE FOR COLLECTING PERSONAL INFORMATION

Generally

We may collect, use, or disclose Personal Information for internal purposes, such as to:

  • Provide you with the Site and Services;
  • Facilitate our work for and on behalf of Clients;
  • Process or complete transactions you requested;
  • Support and improve the Site and Services, including customization and personalization;
  • Develop new Services;
  • Notify you of our products and services via mail, email, telephone, text messaging, web, and/or social media;
  • Communicate with you about the Site, the Services, and other matters via mail, email, telephone, and/or text messaging; and
  • Compile information and analyses to enhance the customer experience and improve our business.

Third-Party Selling & Sharing

We do not sell Personal Information or share Personal Information for cross-context behavioral advertising purposes to any third party for any purpose, including the Personal Information of persons under 16 years of age.


HOW LONG WE RETAIN YOUR PERSONAL INFORMATION 

We retain your Personal Information for as long as we have a relationship, including a prospective relationship, with you and for a period of time after our relationship has ended where there is an ongoing business need to retain it. Our record retention policies are informed by our legal, regulatory, tax, and/or accounting obligations as well as reasonable business needs. If applicable law prohibits retaining Personal Information after a certain period of time, we will not retain Personal Information in violation of such law.


PRIVACY NOTICE CHANGES

This Privacy Notice is subject to change. We encourage you to review this Privacy Notice frequently for any revisions or amendments. Changes to this Privacy Notice will be posted on this Site and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Site or Services.


CONTACT US

If you have any questions about our Site, Services, or this Privacy Notice, please email us at privacy@shiftdigital.com, or send us a letter to the following address:

Shift Digital

Attn: Privacy

348 E. Maple Rd.

Birmingham, MI 48009

UNITED STATES OF AMERICA

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  • 348 E. Maple Rd.
  • Birmingham, MI 48009
  • P: 248.594.2396
  • F: 313.447.4746
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