ItShrt URL Shortener

Effective September 17, 2024
ItShrt ("ItShrt", "we," "us," "our") is dedicated to protecting your privacy. This Privacy Policy outlines how we gather and use, disclose, and protect your information. We created this Policy to inform you on what data we collect, how we collect your data, how we share your data, and your rights around the data. This Policy applies when you use our website ItShrt.com and services, both within and outside the European Union ("EU") and either as creator of a ItShrt Link (as defined below) or clicking on a ItShrt Link.

We may collect and receive information about users of our Services ("users", "you" or "your") from various sources, including: (i) information you provide through your user account on the Services (your "Account") if you register for the Services; (ii) your use of the Services; and (iii) from third-party websites, services, and partners.

For the purposes of this Policy, the Site, features, content, applications, and other services provided by ItShrt will be referred to as the "Services". This Policy works in conjunction with the Site's Terms of Use.

Any capitalized terms used, but not defined, in this Policy have the meanings provided in the Terms of Use. If you do not agree with our policies and practices, please do not use our Services. By accessing or using our Services, you agree to this Policy.

CONTROLLER AND PROCESSOR
Data protection and privacy laws in certain jurisdictions differentiate between "controllers" and "processors" of Personal Data (as defined below). A controller decides the purposes and means of processing personal data, while a processor processes Personal Data on behalf of a controller based on the controller’s instructions. When you create a ItShrt Link (as a "User"), ItShrt acts as a controller. When you click on a ItShrt Link created by a User, we act as a processor. When ItShrt processes Personal Data as a processor on behalf of the User (meaning the creator of a shortened link) and applicable law, namely Regulation (EU) 2016/679 of the European Parliament and of the Council ("GDPR"), requires parties to put in place a Data Processing Agreement (hereinafter, "DPA") to govern such data processing, the DPA attached to these Privacy Policy as Appendix A shall apply. In this case, the DPA set forth in Appendix A shall be incorporated into the Terms of Use and Service Agreement and form an integral part of the Agreement.

PERSONAL DATA
For the purposes of this Policy "Personal Data" means any information that can identify, relate to, describe, be associated with, or link, directly or indirectly, to a particular User. This may include identifiers such as name, identification number, location data, online identifier, or factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. This excludes aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked with you.

HOW WE LEGITIMATELY PROCESS YOUR PERSONAL DATA
ItShrt is entitled to process Users personal data in accordance with the law. The legal basis for collecting and using the Personal Data described below depends on the type of Personal Data involved and the specific context in which it is collected.

Generally, we collect personal data:

When you give us explicit consent to do so;
To execute our contractual obligations to you;
When we have a legitimate interest in processing your personal data that is not overridden by your rights.
Our legitimate interests include operating our Services effectively, communicating with you to provide support, enhancing our platform, conducting marketing activities, and detecting or preventing illegal activities.

In certain circumstances, we may also have a legal obligation to collect personal data from you or may need it to protect your vital interests or those of another person.

When we ask you to provide Personal Data to comply with a legal requirement or to execute a contractual obligation towards you, we will clarify the requirement at that time and inform you whether providing your Personal Data is mandatory, as well as the potential consequences if you choose not to provide it.

WHAT PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT
There are several ways through which you may provide us with your Personal Data.

1) Directly from you:

Account Creation: When you create an account, we collect personal information from you such as your name, email address, and other relevant information (your "Account"). If you create an Account using your login from a third-party account, such as Facebook, Google, Twitter, or Microsoft, we will access and collect your personal information provided by that third-party account. The amount of information that is shared with us from that third-party account depends on your privacy settings on your third-party account.
Create a ItShrt link: By using our Services, Users can create shortened URLs of websites ("ItShrt links"). Users can create ItShrt links without registering for an Account. When you create a ItShrt link, ItShrt collects and stores the original URL and the shortened URL and links it with your session. This applies to both Users who are logged in and to those who are not.
Billing Information: If you add your billing information to your User Account, that information is directed to our third-party payment processor. We do not store your billing information on our systems; however, we have access to, and may retain, subscriber information through our third-party payment processor.
User Support: If you contact us for assistance or support, we may collect your name, email address, or any other content that you send us.
Social Media Interaction: We may collect information from your social media account if you interact with our social media presence.
2) Data Collected Automatically

Log Data: When you use our Services, whether as a registered user or a non-registered user, our servers may automatically record information that your browser sends whenever you create or use a ItShrt link ("Log Data"). This Log Data may include information such as your Internet Protocol ("IP") address, device settings (such as browser type, operating system, language, extensions, etc), the time and date you create the ItShrt Link, the referring website, the time and date of each access, device settings, and analytics on the sharing of the ItShrt Link on third party services, such as on social media. We use this information to monitor and analyze use of the Services, for the Site's technical administration, to increase our Site's functionality and user-friendliness, and to better tailor it to our visitors` needs.
Mobile Devices: We may collect information from your mobile device, such as unique identifying information broadcast from your device when visiting our Services.
Cookies and Similar Technology: "Cookies" are a small data file that we transfer to your computer's hard disk for record-keeping purposes. Please see our Cookie Policy for more information.
3) Personal Data We Collect from Other Sources

Social Media Services: Our Services allow you to interact with social media platforms and other third-party services (e.g., Facebook, Twitter and LinkedIn). If you choose to share your ItShrt links using third-party services, we may collect information related to your use of those third- party services. Additionally, if you access the Services using one of these social media platforms or other third-party services, we may receive information about you from those third parties such as account and profile data. Please note that third-party services may have the ability to restrict the information that is provided to us based on your privacy settings of that account.
NO SPECIAL CATEGORIES OF PERSONAL DATA
In accordance with applicable privacy laws, specifically Article 9 of the GDPR, special categories of personal data comprise any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation (hereinafter "Special Categories of Personal Data")

ItShrt does not request or collect any sensitive Personal Data or Special Categories of Personal Data, as defined by applicable privacy laws, for you to use our Services.

PURPOSES FOR WHICH WE COLLECT AND MAY SHARE YOUR PERSONAL DATA
We collect and may share your Personal Data for the following purposes:

To operate and maintain our Site and provide the Services;
To enrich and personalize our Services;
To process and complete requested transactions;
When it is necessary for our legitimate interests (or those of a third party) and provided that your interests and fundamental rights do not override these interests
Communicating directly with you or through our partners, including for customer service, updates, and other Service related information, as well as for marketing and promotional purposes;
Helping on detecting, preventing, or investigating security incidents, fraud, and other abuse or misuse of our Services; and
Ensuring compliance with our Terms of Service, protecting our legal rights, and meeting regulatory requirements or responding to governmental inquiries.
We have outlined in the chart below a description of the categories of Personal Data we collect, the legal basis for our collection and use of Personal Data, and the categories of third parties with whom some or all of the Personal Data may be shared.

Type of Interaction Collection and Use Applied to    Categories of Personal Information Collected    Purposes for Collection, Use, and Sharing    Categories of Third Parties with Whom Some or All the Personal Information May Be Shared
Users
Identifiers (such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers)
To provide the Services
Customer support
Security and fraud prevention
Ad networks
Analytics services
Technology service providers
Users
Customer Records Information (such as Name, address, telephone number, bank account number, credit or debit card number, other financial information)
To provide the Services
Customer support
Security and fraud prevention
Analytics services
Technology service providers
Users
Commercial information (such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
To provide the Services
Customer support
Advertising
Security and fraud prevention
Ad networks
Analytics services
Technology service providers
Users
Those who click on ItShrts
Internet or other electronic network activity information (such as information regarding a consumer’s interaction with an Internet website, application, or advertisement)
To provide and improve the Services
Ad networks
Analytics services
Technology service providers
Users
Non-Precise Geolocation information (such as zip or area code, state, country)
To provide and improve the Services to you
Fraud and cybersecurity
Ad networks
Analytics services
Technology service providers
Users
Those who click on ItShrt links
Inferences drawn from the above information about your predicted characteristics and preferences
To provide and improve the Services
Analytics
Fraud and cybersecurity
Ad networks
Analytics services
Technology service providers
Users
Other information about you that is linked to the personal information above
To Provide and Improve the Services
Ad networks
Analytics services
Technology service providers
HOW WE MAY SHARE YOUR PERSONAL DATA
The purpose of our Services is to allow you to share information and to receive information on the ItShrts you create. As a result, some Personal Data may be shared with third parties as described below:

ItShrt links You Create: When you create a ItShrt link, the shortened URL and the original URL it refers to is publicly available to anyone provided or with access to the ItShrt link.
Information We Share with Users: We may share the Personal Data we collect as described in this Policy with our Users. When a ItShrt link is created, the User who created the link may be able to view aggregated information about clicks and views of the ItShrt link, including the number of times the ItShrt link was shared, whether or not it was viewed, comparison of that ItShrt link’s performance to that of all ItShrt links pointing to the same content, whether others are sharing a ItShrt link to the same content, geographic regions where the content is being viewed, and identification of social networks or websites on which the ItShrt link appears.
Service Providers: We may employ third party companies and individuals to facilitate our Services, to provide the Services on our behalf, to improve our Services and to perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics, payment processing, fraud detection and improvement of the Site's features) or to assist us in analyzing how our Site and Services are used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics and Search Engine Providers: We may share Personal Data with analytics and search engine providers that assist us in the improvement and optimization of the Service.
Feedback: We may collect feedback from you about your experience to compare your experience with other Users of the Services to improve the quality of the Services. This feedback is the property of ItShrt, and we reserve the right to share it with any third-party.
Acquisition, merger, or bankruptcy: ItShrt may sell, transfer, or otherwise share some or all its assets, including your Personal Data, in connection with a merger, acquisition, reorganization, sale of assets, or in the event of bankruptcy.
Disclosures without Your Consent: We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in the event of an emergency, to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or act regarding possible illegal activities, suspected fraud, the safety of person or property, or a violation of our policies.
Disclosures with Your Consent: We will share information about you when you instruct us to do so, such as when you share ItShrts or content with others through the Services or if we notify you that the information you provide will be shared in a particular manner and you provide such information (such as posting it to a third-party service).
We may also share aggregated information that does not include Personal Data and we may otherwise disclose non-identifying information and Log Data to parties for industry analysis, demographic profiling, and other purposes. Any aggregated information shared in these contexts will not contain your Personal Data.

MARKETING AND ADVERTISING
We process your Personal Data to tailor our marketing and advertising efforts. To do this, we provide your information to third party advertising networks (such as Google Doubleclick) and social media companies (such as Facebook, Instagram, and other social media platforms). When we provide data to agencies, ad networks, and other parties for targeted advertising, we do not provide them with your name, financial information, or any sensitive information. We use online identifiers such as email, cookies, and device identifiers to help us provide targeted advertising to you and others like you.

We may also use aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the Personal Data we have collected from you to enable us to display advertisements to target audiences.

To opt out of targeted advertising, you may use the following links provided by third parties that manage opt outs for some ad networks:

http://preferences-mgr.truste.com
http://www.networkadvertising.org/managing/opt_out.asp
http://www.aboutads.info/
https://policies.google.com/privacy/partners
WE DO NOT TRACK SIGNALS
Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do regarding these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or act with respect to "Do Not Track" signals.

EMAIL MARKETING
If you sign up for our Services or newsletter, we will send you marketing emails. If you change your mind, you can opt-out at any time by selecting the unsubscribe option when you receive an electronic marketing communication from us. The withdrawal of your consent will not impact the lawfulness of processing based on your consent prior to the withdrawal.

Please note that even if you opt-out of receiving commercial emails, you will still receive emails that are transactional in nature, such as actions taken on your account, updates to our online policies, and other transactional communications.

INTERNATIONAL TRANSFERS
When you use our Services, your Personal Data may be transferred to our service providers and trusted partners who maintain processing facilities outside the European Economic Area ("EEA"). This is only for the purposes of providing, and to the extent necessary to provide, the Services to you. The privacy laws in these countries may not be as protective with your information as the laws in your jurisdiction.

Nonetheless, ItShrt has taken steps to ensure robust security for your Personal Data, including the use of Standard Contractual Clauses ("SCCs"), to guarantee that your data is adequately protected during transfers.

RETENTION OF YOUR PERSONAL DATA
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

YOUR PERSONAL DATA RIGHTS
If you have questions about how ItShrt handles your Personal Data or would like to exercise your rights under applicable data protection laws, you may make a request by clicking here or by contacting us at info@itshrt.com. You have the following rights in relation to your Personal Data:

If you wish to access, correct, update, or request deletion of your Personal Data, you can do so at any time by making a request clicking here or emailing info@itshrt.com. Please note that, in case of exercising your deletion rights you may no longer be able to use the Services unless you create a new account with us.
You will not be discriminated against for exercising your data rights.
To exercise your rights to deletion of your personal data under the GDPR or other data protection laws, you may deactivate your account via your control panel settings. Once a deactivation request is made, personal data associated with your account will be removed within 30 days. Please note that while some personal data may be retained in immutable backups for up to 180 days, it will not be accessible or used after the removal request is processed. Certain data, such as ItShrt links, may remain active unless specifically requested for removal.
In addition, you can object to the processing of your personal data, ask us to restrict the processing of your personal data, or request portability of your personal data. Again, you can exercise these rights making a request clicking here or emailing info@itshrt.com.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing, please make a request by clicking here or contacting us by email at info@itshrt.com.
Similarly, if we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority. Contact details of authorities in other EU Member States can be found in the directory maintained by the European Data Protection Board ("EDPB"), as required under the GDPR, here.
Please note that when certain requests will be subject to necessary verification requirements. Only you or someone legally authorized to act on your behalf may exercise these rights, We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.

You do not need to create an account with us to exercise your Right to Know or Right to Delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only process Personal Data provided in the request to verify the requestor’s identity or authority to make it.

PERSONAL DATA SALES OPT-OUT AND OPT-IN RIGHTS
ItShrt does not sell Personal Data to third parties for monetary value. However, to the extent that “sale” is interpreted under applicable laws to include interest based advertising or other data uses described in the “Purposes for which we Collect and may Share your Personal Data” and “How We May Share Your Personal Data” Sections above, we will comply with those laws in regards to those activities. You can read more in our Cookie Policy.

To exercise the Right to Opt-Out, you (or your authorized representative) may submit a request to us by filling out the webform available here or by emailing us at info@itshrt.com.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Data sales.

You do not need to create an account with us to exercise your Right to Opt-Out. We will only use Personal Data provided in an opt-out request to review and comply with the request.

Please note that your decision to opt out of the sale of your Personal Data may impact the availability and quality of some of our Services provided to you. Furthermore, your Personal Data may still be shared pursuant to the terms of the Policy, where such sharing does not constitute a sale.

The security of your Personal Data is important to us. As such, ItShrt uses standard physical, technical, and administrative measures designed to reduce risk of loss, misuse, unauthorized access, disclosure, or modification of your Personal Data. Unfortunately, no system or network can be guaranteed to be 100% secure, as such we cannot and do not guarantee or warrant the security of any information that you transmit on or through the Services or that we otherwise maintain.

SECURITY
ItShrt is committed to protecting your information. To do so, we employ a variety of security technologies and measures designed to protect information from unauthorized access, use, or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data. Please note that no service is completely secure. While we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur.

NOT DIRECTED TO CHILDREN
Our Services are not directed persons under 18. We do not knowingly collect information from persons under 18. As such, we do not knowingly “sell,” as that term is defined under applicable law, including the CCPA, the Personal Data of minors.

If you are a parent or guardian of a minor who is under 16 years old and using our Services, you may contact us at info@itshrt.com to request and arrange for deletion of any Personal Data, if any, we may have collected about the minor.

For privacy reasons we may request proof of relationship to the minor.

UPDATES TO THE PRIVACY POLICY
We may update this Policy from time to time. When we update the Policy, we will notify you by updating the “Effective Date” date at the top of this Policy, posting the new Policy, and providing any other notice required by applicable law. We recommend that you review the Policy each time you visit the Site to stay informed of our privacy practices. If we materially change the ways in which we process or share Personal Data previously collected from you through our Services, we will notify you.

If you do not agree or consent to these updates or changes, do not continue to use the Services.

LINKS TO THIRD PARTY WEBSITES
Our Services, email updates, and other communications may, from time to time, contain links to and from the websites of others, including our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.