Introduction

Shutta Limited (“We”, “Shutta” or “s.i.m.b.a“) is a strong supporter of data privacy and is committed to protecting the privacy of individuals with whom we interact. This privacy policy (“Privacy Policy“) is designed to answer your questions about the information we collect from or about you, how we collect such information, how we use that information, with whom we do or do not share that information, the rights you have with regard to the information we collect, and how you can exercise your rights regarding your personal information.

Controller

For information we collect through the Website and the services provided through the Website, Shutta determines how that data is Processed and Shutta is the Controller. You may contact Shutta with any questions about how we Process your personal information using the information in the Contact Us section below.

Scope

This Privacy Policy applies to all information we collect on, through, or as a result of your use of the website accessible at simba.asia (the “Website“) and any other websites, applications, or addons provided by Shutta that incorporate this Privacy Policy.

This Privacy Policy does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website, nor does it apply to information collected by Shutta offline or through any other means not identified here.

Table of Contents

• Binding Agreement
• Information We Collect
• How We Collect Information
• How We Use Your Information
• Sharing or Selling Your Information
• Online Tracking Technologies and Advertising
• Cookie Policy
• Your Choices with Tracking and Advertising Technologies
• Your Information / Your Choices
• Exercising Your Rights
• Data Security and Practices
• Global Data Transfer, Storage, and Processing Practices
• Retention
• Updates to This Privacy Policy
• Third Party Websites
• GDPR Compliance Statement
• Contact Our Data Protection Officer
• Contact Us

Binding Agreement

Please read this Privacy Policy carefully to understand how we Process your information as well as the rights you may have regarding your information. “Process” or “Processing” your information includes collecting, using, storing, disclosing, and otherwise manipulating your information. By accessing or using this Website, you agree to us collecting and Processing your personal information as described in this Privacy Policy. This Privacy Policy may change from time to time (see Updates to This Privacy Policy). The date the Privacy Policy was last modified is set forth above. Your continued use of this Website after we make changes to this Privacy Policy is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Information We Collect

We collect different information from you depending on whether you are a visitor or a customer. All information we collect is either “personal information” or “non-identifying information.”

“Personal information” is information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, postal address, email address, and telephone number. When anonymous information is directly or indirectly associated with personal information, we treat the resulting information as personal information.

“Non-identifying information” is information that does not directly or indirectly identify and cannot reasonably be used to identify an individual.

We may use personal information and non-identifying information to create “aggregated information”, which is information about groups or categories of data subjects or individuals, which does not identify and cannot reasonably be used to identify an individual. We do not treat aggregated information as personal information.

How We Collect Information

We collect information:

• Directly from you when you provide it to us, such as when you contact us, create an account, and/or purchase our services.
• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.

Information You Provide to Us Includes:

• Information that you provide at the time you create an account on the Website and/or subscribe to our services, such as your first and last name, email address, phone number, and billing address.
• Information you provide when you contact us through the website, such as first and last name, email address, phone number, and any information you include in the message field.
• Information you provide when you contact us by email regarding us, our products and services, your subscription, or the Website. We may retain records and copies of your correspondence with us (including email addresses) in order to fulfill your request and/or provide customer support to you.
• Details of transactions you carry out through our Website and of the fulfillment of your subscription to our services. You may be required to provide financial information to our third-party service provider, Stripe, before placing an order through our Website. We use Stripe Subscriptions to manage payments, and Stripe may store your credit card information on its platform. We will not have access to any financial information provided to or stored by Stripe. For more information about how Stripe treat your financial information, please see:

• https://stripe.com/privacy

Information We Collect Automatically Using Various Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. We associate this information with an anonymous ID. The information we collect automatically includes:

• Details of your visits to our Website, including traffic data, location data (down to the city or metro area), pages visited, time spent on the Website, and download history when, for example, you download one of our resources offered on the Website.
• Information about your computer, mobile device, and internet connection, including your IP address, operating system, and browser and device type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please see Online Tracking Technologies and Advertising for information on how you can opt out of online or behavioral tracking and for more information on how we respond to web browser signals and mechanisms to automatically collect information.

We may associate the information we collect automatically with personal information we collect in other ways, such as personal information you provide to us or that we receive from third parties. This helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

Information We Collect Using Analytics Tools

Analytics tools are a specific type of automatic data collection tools. We use Google Analytics, a tracking and analytics tool, in conjunction with our Website. We use Google Analytics to track, collect, and analyze information regarding your visits to our Website, including what you do on the Website and how you access the Website.

For more information on our other automated tools, see Online Tracking Technologies and Advertising and Cookie Policy.

Information We Collect from Third Parties

We may supplement or update the information you provide to us or that we collect automatically, using information provided to us by third parties.

Sensitive Personal Information

We do not collect “Sensitive Personal Information,” which includes: race or ethnicity; religion; citizenship; genetic data; biometric data used to identify a person; precise geolocation; personal information of children; union membership; SSN; DL or passport number; financial account with password or security code; contents of mail, email or texts (unless a business is the intended email recipient); medical and health information that does not otherwise constitute Personal Health Information (or “PHI”); and in the EU, criminal records.

Information Collected between December 2022 and December 2023

During the above time period, we have collected the following types of information about users of our Website:

Category	Examples	Collected
Identifiers	Name, postal address, IP address, email address, account name, or other similar identifiers	YES
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Name, address, telephone number, bank account number, credit card number, debit card number, or any other financial information	Only phone number
Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)	NO
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	NO
Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data	NO
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement	YES
Geolocation data	Physical location or movements	NO
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	NO
Professional or employment-related information	Current or past job history or performance evaluations	NO
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records	NO
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	NO

How We Use Your Information

Consistent with applicable law and the choices and controls that you select when Exercising Your Rights, we may use your information for the purposes described in this Privacy Policy, including but not limited to:

• Fulfill any purpose for which you present the information to us, such as allowing you to create an account, make purchases, contact us, or receive customer support.
• Present our Website and its contents to you.
• Provide you with the materials, products, and services you request, view, download, or purchase.
• Enable you to maintain an account on our Website, to use our services, and make purchases.
• Communicate with you about your account or transactions with us, including providing you with notices about your account, including password expiration and renewal notices.
• Send you information or request feedback about our products, services, features on our Website, or changes to our policies, including this Privacy Policy.
• Send you offers and promotions for our products and services.
• Personalize content on the Website.
• Provide you with targeted advertising based on your activity on our Website.
• Provide you with information on our own or third-party products or services based on your activity on our Website.
• Operate, understand, optimize, develop, or improve our Website, products, services, and operations, including by using visitor survey, research, and analytics tools like Google Analytics.
• Detect, investigate, and prevent activities that may violate our policies, pose safety issues, or be fraudulent or illegal.
• Test, research, analyze, and conduct product development, including the development and improvement of our Website, products, services, and promotional campaigns.
• Notify you of product recalls or safety issues.
• Enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you about changes to our Website or any products or services we offer or provide.
• Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Shutta Limited’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets being transferred.
• For other purposes we may inform you about when you provide the information.
• For any other purpose with your consent.
• For any purpose consistent with this Privacy Policy.
• To learn more about how we use your information for personalization and tracking, please see Online Tracking Technologies and Advertising.

Our Legal Basis for Processing Your Data

Processing your data enables us to run our business efficiently and safely, improve our Website, products, and services, manage and maintain your account, enter into and complete transactions with you, communicate with you, and comply with our legal obligations.

We rely on several different legal bases to Process you information, including:

• The Processing is necessary to perform our contractual obligations in our contracts with you (such as fulfilling the orders for subscriptions you place through the Website).
• The Processing is necessary to communicate with you in response to your request or regarding your account or order.
• You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes that we may obtain your consent for from time to time).
• The Processing is necessary to comply with a legal obligation, a court order, or subpoena, or to exercise or defend legal claims.
• The Processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing the Website or our products, preventing fraud and cheating, and promoting safety and security as described in this Privacy Policy.

Sharing or Selling Your Information

It is our policy to not sell your personal information with third parties. However, we may disclose your personal information to other businesses or entities where it is required in order for us to perform our obligations under our contract with you, where it is required to provide the products or services you requested, where it is required by law, or where we have another legitimate interest in doing so. Such disclosures may be considered a sale under some state or international laws. We may disclose your personal information, including but not limited to the following:

• To fulfill the purpose for which you provided it.
• To our subsidiaries and affiliates only for use in the manner described in this Privacy Policy.
• When you direct us to share your personal information with a third party to fulfill your request.
• To vendors, consultants, contractors, service providers, and other third parties that perform services on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data about how you interact with the Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. Unless described in this Privacy Policy, we do not share, sell, rent, or trade any of your personal information with third parties for their promotional purposes.
• To law enforcement agencies, regulators, and courts in response to a court order, subpoena, regulatory requirements, or similar legal process, to report any activities we reasonably believe to be unlawful, or as otherwise required by law.
• To combat fraud or criminal activity, and to protect our rights, users, and business partners, or as part of legal proceedings affecting Shutta Limited.
• To another entity in connection with a merger, transfer of data assets, reorganization, divestiture, financing, dissolution, or similar corporate event involving all or part of our business.
• To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Shutta Limited, our customers, or others.
• Where it is necessary to respond to a public health emergency or in an emergency to protect the safety of your health and property.
• To a reasonable extent for purposes of carrying out news reporting and media monitoring for public interests.
• For any other purpose we disclosed when collecting the information.
• With your consent.

Aggregated or Non-Identifying Information

We may disclose aggregated information or non-identifying information for any reason without restriction.

Disclosures between December 2022 and December 2023

We do not sell personal information. However, there may be instances in which our disclosure of your personal information to a third party is considered a “sale” under certain state or international laws. We do not collect, share, or sell the personal information of individuals we know are under age 16.

During this time, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

Personal Information Category	Category of Third-Party Recipients
Identifiers	Affiliates, Service Providers, Business Partners]
California Customer Records personal information categories	Affiliates, Service Providers, Business Partners]
Protected classification characteristics under California or federal law	None
Commercial information	None
Biometric information	None
Internet or other similar network activity	Affiliates, Service Providers, Business Partners
Geolocation data	None
Sensory data	None
Professional or employment-related information	None
Non-public education information	None
Inferences drawn from other personal information	None

We may, however, sell certain anonymized advertising data to third parties. This anonymous data includes account-level information about a particular account’s interaction with advertising platforms, such as Google Ads and Facebook Ads, including advertising spend data. This data is anonymized such that no particular user or entity can be identified, shared, or revealed. It is never associated with any of your personal information.

Sensitive Personal Information

We do not collect, store, sell (if considered a sale under applicable state privacy laws), share, and/or disclose Sensitive Personal Information.

Online Tracking Technologies and Advertising

We, as well as third parties that provide content or other functionality for our Website, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. These technologies allow us to understand who has interacted with us and also help us to operate our Website more efficiently. These technologies also help us:

• Provide useful features to simplify your experience when you return to our Website (for example, remembering your shipping information for future purchases).
• Deliver relevant content and advertising based on your preferences, usage patterns, and location.
• Monitor, evaluate, and optimize the use and operation of our Website.
• Analyze traffic on our Website.

Cookies. For more information on cookies, please see our Cookie Policy below.

Web beacons and marketing pixels. Web beacons and marketing pixels are small pieces of data that are embedded in images on the pages of sites. They may also be referred to as clear gifs, pixel tags, and single-pixel gifs. In some cases, they permit us to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). They may involve the transmission of information directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use web beacons or marketing pixels to bring together information we collect about you.

Analytics. We use Google Analytics, Google Ads, and Facebook Ads to collect information regarding visitor behavior and visitor demographics for our Website. For more information on how Google uses your information, please see Google’s Privacy Policy at https://policies.google.com/privacy?hl=en-US and Google’s Advertising Policy at https://policies.google.com/technologies/ads?hl=en-US. For more information on how Facebook/Meta uses your information, please see Facebook/Meta’s Privacy Policy at https://www.facebook.com/privacy/policy.

Social Media. Our Website may include links to social media websites like YouTube, Twitter/X, LinkedIn, and Facebook. When you click on one of these links, these social media companies may recognize you and collect information about your visit to our Website, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies. For information, please consult the following policies:

• YouTube (https://policies.google.com/privacy)
• Twitter/X (https://twitter.com/en/privacy)
• LinkedIn (https://www.linkedin.com/legal/privacy-policy)
• Facebook/Meta (https://www.facebook.com/privacy/policy)

Privacy Policy for YouTube

For those users of our YouTube data connector, please note that the API uses YouTube API Services.  Refer to the Google Policy for more information.

To revoke our access to your YouTube data, see the following link.

Cookie Policy

Overview

Cookies are pieces of information that are placed on the hard drive of your computer when you visit our Website. 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 may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies. Cookies may involve the transmission of information from us to you and from you directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use cookies to bring together information we collect about you. You can choose to have your computer warn you each time a cookie is being placed on your device, or you can choose to block all cookies. You do this through your browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. If you turn cookies off, you won’t have access to many features that make your visitor/user experience more efficient, and some of our services will not function properly.

Categories of Cookies

There are different ways to classify cookies, including based on when they expire or whether they are managed by us or a third party.

Type of Cookie	Description
Persistent Cookies	Persistent Cookies stay on your computer or mobile device until you delete them.
Session Cookies	Session Cookies expire once you close your web browser.
First Party Cookies	First Party Cookies are those that may be managed by Shutta Limited and originate from our Website.
Third Party Cookies	Third Party Cookies originate with service providers or business partners providing services on or through our Website and can be used by these third parties to recognize your device when it visits other websites. Third Party Cookies may also be used for other purposes such as analytics, advertising, and social media features. We currently utilize Third Party Cookies from Google and Hubspot.
Strictly Necessary	These cookies are necessary for the Website to function and cannot be switched off in our systems. Strictly necessary cookies are typically set in response to actions or services that you request such as setting your privacy preferences, logging in, filling out a form, or putting items in a shopping basket. Strictly necessary cookies can also be used to manage sessions on load-balanced servers or to ensure user requests are routed consistently to the correct server. You can set your browser to block these cookies or to alert you about these cookies, but some parts of the Website will not work if you select such settings.
Performance or Analytics Cookies	Performance cookies are sometimes called analytics cookies. These cookies count visits and traffic sources so the performance of our Website can be measured and improved. These cookies help us to know which pages are the most and least popular on the Website and to see how visitors move around the Website. For example, we use Google Analytics to help us understand how frequently the same people revisit the Website, how the Website is found, and which pages are most frequently viewed. All information collected through these performance cookies is aggregated and anonymous.
Functional Cookies	Functional cookies are anonymous and do not track browsing activity across other websites. Examples include cookies that remember user location, chosen language, or other settings to provide a personalized user experience on a website.
Tracking, Marketing, and Advertising Cookies	We may partner with third-party advertisers who may use tracking pixels that set cookies to assist with delivering online advertising relevant to your interests. You can opt-out of almost all advertising cookies by updating your preferences on www.aboutads.info.

Why do we use cookies?

We use cookies to learn how you interact with our Website and to improve your experience and provide you additional functionality on the Website. Certain things we do using cookies include remembering your language preference, remembering products in your cart, and providing you with content and advertisements consistent with your interests.

What type of cookies do we use?

We use Functional Cookies, Performance/Analytics Cookies, and Advertising Cookies. See below for a listing of the cookies we use on our Website.

Cookie	Domain	Description	Duration	Type
sbjs_migrations	.simba.asia	Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website.	session	Analytics
sbjs_current_add	.simba.asia	Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website.	session	Analytics
sbjs_first_add	.simba.asia	Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website.	session	Analytics
sbjs_current	.simba.asia	Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website.	session	Analytics
sbjs_first	.simba.asia	Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website.	session	Analytics
sbjs_udata	.simba.asia	Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website.	session	Analytics
sbjs_session	.simba.asia	Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website.	1 hour	Analytics
tk_or	.simba.asia	JetPack plugin sets this referral cookie on sites using WooCommerce, which analyzes referrer behaviour for Jetpack.	1 year 1 month 4 days	Analytics
tk_r3d	.simba.asia	JetPack installs this cookie to collect internal metrics for user activity and improve user experience.	3 days	Analytics
tk_lr	.simba.asia	JetPack plugin sets this referral cookie on sites using WooCommerce, which analyzes referrer behaviour for Jetpack.	1 year	Analytics
_gcl_au	.simba.asia	Google Tag Manager sets the cookie to experiment advertisement efficiency of websites using their services.	3 months	Analytics
__cf_bm	.hubspot.com	This cookie, set by Cloudflare, is used to support Cloudflare Bot Management.	1 hour	Necessary
_cfuvid	.hubspot.com	No description	session	Other
__cf_bm	.hsforms.com	This cookie, set by Cloudflare, is used to support Cloudflare Bot Management.	1 hour	Necessary
_cfuvid	.hsforms.com	No description	session	Other
_ga_*	.simba.asia	Google Analytics sets this cookie to store and count page views.	1 year 1 month 4 days	Analytics
_ga	.simba.asia	Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors.	1 year 1 month 4 days	Analytics
bcookie	.linkedin.com	LinkedIn sets this cookie from LinkedIn share buttons and ad tags to recognize browser IDs.	1 year	Advertisement
li_gc	.linkedin.com	Linkedin set this cookie for storing visitor’s consent regarding using cookies for non-essential purposes.	6 months	Functional
lidc	.linkedin.com	LinkedIn sets the lidc cookie to facilitate data center selection.	1 day	Functional
_fbp	.simba.asia	Facebook sets this cookie to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising after visiting the website.	3 months	Analytics
messagesUtk	.simba.asia	HubSpot sets this cookie to recognize visitors who chat via the chatflows tool.	6 months	Functional
__hstc	simba.asia	Hubspot set this main cookie for tracking visitors. It contains the domain, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).	6 months	Analytics
hubspotutk	simba.asia	HubSpot sets this cookie to keep track of the visitors to the website. This cookie is passed to HubSpot on form submission and used when deduplicating contacts.	6 months	Analytics
__hssrc	simba.asia	This cookie is set by Hubspot whenever it changes the session cookie. The __hssrc cookie set to 1 indicates that the user has restarted the browser, and if the cookie does not exist, it is assumed to be a new session.	session	Necessary
__hssc	simba.asia	HubSpot
sets this cookie to keep track of sessions and to determine if HubSpot should increment the session number and timestamps in the __hstc cookie.	1 hour	Necessary
_GRECAPTCHA	www.google.com	Google Recaptcha service sets this cookie to identify bots to protect the website against malicious spam attacks.	6 months	Necessary
test_cookie	.doubleclick.net	doubleclick.net sets this cookie to determine if the user’s browser supports cookies.	15 minutes	Advertisement
rc::a	google.com	This cookie is set by the Google recaptcha service to identify bots to protect the website against malicious spam attacks.	never	Necessary
rc::f	google.com	This cookie is set by the Google recaptcha service to identify bots to protect the website against malicious spam attacks.	never	Necessary
wpEmojiSettingsSupports	simba.asia	WordPress sets this cookie when a user interacts with emojis on a WordPress site. It helps determine if the user’s browser can display emojis properly.	session	Necessary
rc::c	google.com	This cookie is set by the Google recaptcha service to identify bots to protect the website against malicious spam attacks.	session	Necessary
rc::b	google.com	This cookie is set by the Google recaptcha service to identify bots to protect the website against malicious spam attacks.	session	Necessary

How Do Third Parties Use Cookies on our Website?

We work with third parties to provide certain services on the Website. These third parties may include Hubspot, Meta, Google, Twitter/X, and LinkedIn.

Third parties may use their own cookies to collect information about your actions on our Website and/or the advertisements you click on. They may use this information to deliver advertisements they believe are most likely of interest to you based on content you have already viewed. Third parties may also use this information to measure the effectiveness of certain advertisements. We do not control such third party cookies. For more information on how some of our third party service providers collect and use information please refer to their websites privacy policies provided above.

How do I Control Cookies?

If you choose, you can set your browser to reject cookies or you can manually delete individual or all of the cookies on your computer by following your browser’s help file directions. However, if you manually delete cookies, this may alter your access and use of some of the pages and features on our Website.

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

• https://support.google.com/chrome/answer/95647 (Chrome)
• https://support.mozilla.org/en-US/kb/enhanced-tracking-protectionfirefox-desktop (Firefox)
• https://help.opera.com/en/latest/security-and-privacy/ (Opera)
• https://support.microsoft.com/en-gb/help/17442/windows-internetexplorer-delete-manage-cookies (Internet Explorer)
• https://support.apple.com/en-gb/guide/safari/manage-cookies-andwebsite-data-sfri11471/mac (Safari)
• https://support.microsoft.com/en-gb/help/4468242/microsoft-edgebrowsing-data-and-privacy (Edge)

You may also visit https://allaboutcookies.org/ or https://www.aboutcookies.org/ for details on how to delete, reject, or block cookies and for further information on cookies generally.

Blocking all cookies will have a negative impact upon the usability of many websites, including ours. If you block cookies, you will not be able to use all the features on our website.

Your Choices with Tracking and Advertising Technologies

It is our goal to provide you with choices regarding how the personal information you provide to us is used. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, please note that if you disable or refuse cookies, some parts of the Website may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising: If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can contact us and notify us that you wish to opt-out of third-party advertising. However, please note that we currently do not share non-anonymous information with third parties for advertising purposes. We will update this policy if we decide to do so.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) by visiting https://thenai.org/.

You may have additional rights regarding your personal information based on the state or country in which you reside. Please see Jurisdiction-Specific Rights for more information.

Your Information / Your Choices

We provide you the ability to exercise certain controls and choices regarding our collection, use, and sharing of your information. Residents of certain states or countries may have other rights and choices. Please see the Jurisdiction-Specific Rights section at the end of this Privacy Policy.

In accordance with applicable law, your controls and choices may include:

Right to Know/Right to Access

You have the right to know what personal information we have collected about you. Upon receipt of your request, and confirmation of your identity, we will disclose to you:

• The categories and specific pieces of personal information that we have collected about you in the past twelve (12) months.
• The sources from which we have collected that information.
• Our business or commercial purpose for collecting such information.
• The categories and specific pieces of personal information that we have disclosed to third parties for a business purpose during the past twelve (12) months.
• The categories and specific pieces of personal information that we have sold to third parties during the past twelve months.
• The third parties to whom we have disclosed or sold such personal information.

In most cases, you may request this information up to two times each year.

Right to Data Portability

You have the right to request a copy of the personal information we have about you. We will provide it in a format that we select, that you can reasonably transfer to a third party.

Right to Correct/Right to Rectification

You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.

Right to Delete/Right to Erasure

You have the right to request that we delete any of your personal information, subject to applicable legal exceptions. If you submit a request for your personal information to be deleted, we will review your request and attempt to confirm your identity. If we confirm your identity, we will review the request to see if an exception allowing us to retain the information applies. If no exception applies, we will delete your personal information and direct our service providers to do the same.

We may deny your deletion request, for example, if retaining the personal information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with any international, national, federal, state, or local laws, rules or regulations, applicable to us or to your personal information.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Opt-Out of Promotional Offers

If you do not wish to have your email address or other contact information used by Shutta to promote our products or services, you can opt-out of non-essential email or text communication by contacting us as provided in the Contact Us section. If we have sent you a promotional email or text, you may send us a return email or text asking to be omitted from future email distributions.

Your election not to receive promotional and marketing correspondence from us will not (a) preclude us from corresponding with you, by email, text or otherwise regarding your existing or past relationship with us, nor (b) preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your personal information while maintaining and improving the Website.

Data Security and Practices

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect visitor information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods.

While we do our best to protect your personal information, please be aware that no security measures are perfect or impenetrable. If you know or have reason to believe that your personal information has been lost, stolen, misappropriated, or otherwise compromised, please contact us.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Global Data Transfer, Storage, and Processing Practices

Shutta Ltd has its headquarters in Hong Kong, and the servers on which we store data are located in Singapore. We may store or Process your personal information in locations around the globe for the purposes described in this Privacy Policy.

Wherever your personal information is transferred, stored, or Processed by us, we will take reasonable steps to safeguard the privacy of your personal information. These steps may include implementing standard contractual clauses where recognized by law (e.g., the Standard Contractual Clauses approved by the European Commission), obtaining your consent, or other lawful means of transferring personal information. By using our Website or our services, you acknowledge that your personal information will be stored or Processed in Singapore. If you have any concerns about how your data is being transferred, stored, or Processed, please contact us at info@shutta.co.

Retention

We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this Policy will require us keeping your personal information for longer than one (1) year from the moment of last given consent.

When we have no ongoing legitimate business need to Process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further Processing until deletion is possible.

Updates to This Privacy Policy

From time to time, we may change this Privacy Policy to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. Any changes to this Privacy Policy will be posted to this page, and the date the Privacy Policy was last revised will be identified at the top of the page. Where required by applicable law, we will obtain your consent.

Third Party Websites

Any links to third-party websites on our Websites are provided solely as a convenience to you. We do not endorse or make any representations about these websites or any products, materials, or services offered through those websites. Any personal information you provide on these third-party websites is subject to the privacy practices and policies of those websites, and we recommend you review their privacy practices. We do not accept any responsibility or liability for the privacy practices or content of any websites or services that are not operated by or for us.

GDPR Compliance Statement

We respect and endeavor to comply with the EU and UK General Data Protection Regulations (GDPR). Some of the key ways we strive to comply with these regulations are:

• Consent – We explain what you’re consenting to clearly and without ‘legalese’, and ask that you explicitly consent to contact from us.
• Breach Notification – In the event of a breach we will notify affected users within seventy-two (72) hours of first having become aware of the breach.
• Your Rights – We explain your privacy rights to you and provide options for you to exercise these rights (see the European Economic Area (GDPR – EEA) and United Kingdom (GDPR UK) sections below).
• Privacy by Design – We have implemented technical and organizational measures that we consider to be appropriate and effective in meeting the requirements of GDPR – EEA and GDPR UK and protecting the rights of data subjects. We hold and Process only the data absolutely necessary for the completion of our duties (data minimization), and we limit the access to personal data to those needing to act out the Processing.

Contact Our Data Protection Officer

Should you wish to report a complaint or if you feel that our company has not addressed your concern in a satisfactory manner, you may contact our Data Protection Officer in writing using the following contact information:

Attn: James Shimell, Shutta Limited
Unit 1603, 16th Floor, The L. Plaza, 367 – 375 Queen’s Road Central, Sheung Wan, Hong Kong.

If you need additional assistance or have a concern regarding a decision made by our Data Protection Officer, you have a legal right to contact the European Data Protection Board in your country of residence. For more information, please visit https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Contact Us

If you have any comments, questions, concerns about this Privacy Policy or our privacy practices, please contact us by:

• Calling us at +84 903 106 993.
• Emailing us at simba@shutta.co.
• Writing to us at:
  Attn: James Shimell, Shutta Limited
  Unit 1603, 16th Floor, The L. Plaza, 367 – 375 Queen’s Road Central, Sheung Wan, Hong Kong.