Last updated: 15th of November 2023.

If you're looking for our Terms of Service, it's here.

With Shelf, we believe your data belongs to you. We built our service to protect your rights and give you more control over your digital life.

You can read more about our stance on data rights here.

Lots of legal talk here, but if you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at: support@koodos.com. Koodos, Inc. and its affiliates respect your privacy and are committed to protecting it. We provide the Privacy Policy to inform you of our policy and practices and of the choices you can make about the way your information is collected and used.

An additional privacy note for our EU users can be found here.

Personal Information We Collect

Shelf Account Information. We collect the following types of Shelf Account Information in connection with your use of the Service:

• Account Information:  When you create an account with us, we may, depending on the information provided by your service provider(s) in logging in, collect information such as your name, email address, relay email address, public cryptocurrency wallet address, wallet type, profile picture, identity verification details, and other information that you voluntarily choose to provide to us in connection with the Service.

• Third-Party Account Information:  Our Services may provide you with functionality to export or otherwise receive your personal information from third-party services, such as Spotify, and others. If you use our Service to export such Third-Party Account Information or otherwise provide such information to us, we will store and use such Third-Party Account Information in accordance with this Privacy Policy.

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Additional information you provide to us:

• Feedback or correspondence: when you contact us with questions, feedback, product reviews, or otherwise correspond with us online, we collect information including your full name, email address, telephone number and the content of your communications.

• User Submitted Content:  Certain portions of the  Services may allow you to submit unstructured data, text, messages, files,  images, videos, or other content to Shelf for processing.  We collect personal information from you to  the extent your submissions to Shelf contain personal information and we will  only use such personal information in accordance with this Privacy Policy.    

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Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state, or geographic area.

• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

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We use the following tools for automatic data collection:

• Cookies, which are text files stored on your device to uniquely identify your browser or to store information or settings in the browser to help you navigate between pages efficiently, remember your preferences, enable functionality, help us understand user activity and patterns, and facilitate online advertising.

• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

  
  

  Over time, Shelf will provide its users (“users”) with personal data stores, which enable them to store data and choose who to share that data with and when to share it. A personal data store can be owned and controlled by a single individual or by an organization or legal entity. 
  

How We Use Your Personal Information

We may use your personal information as specified below:

To operate our Services. It is in our legitimate business interests to use your personal information to:

• Provide, operate, and improve our Services and our business;

• Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages;

• Provide support, and respond to requests, questions, and feedback.

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‍For research and development. It is in our legitimate business interests to analyze and improve the Services and to develop new products and services, including by studying use of our Services.

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For marketing.  If you have signed up or otherwise elected to receive marketing communications, we may collect and use your personal information for marketing and advertising purposes. For example, we may from time-to-time send you direct marketing communications via email and text message, including, but not limited to, and notifying you of offers or account updates. You may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.

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To comply with law. Shelf may use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

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For compliance, fraud prevention, and safety. We may use your personal information to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern our Services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

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To create anonymous data. We may use your personal information to create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by restructuring it or removing information in a way that makes the data personally identifiable to you. With your explicit consent, we may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services, conduct research, and promote our business.

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Storing and Processing Data on Behalf of Our Users
Over time, Shelf will enable its Users to store their own data in a personal data store. In doing so, Shelf empowers its Users to determine what data they will store, if that data should be shared and with whom, and for what purposes.

When a User uses a personal data store to store their own data, the User acts as the data controller and Shelf processes personal data on the User’s behalf, as a data processor. Shelf does not use this User data for any purposes other than to provide the contracted services and we do not share User data with third parties except for the limited purposes described below.

Clients have the responsibility to understand what data they are storing in their personal data store, whom that data is shared with, and what, if any, data they have made public.

When you use our Services, you may be able to provide your Shelf Account Information to other businesses (“Third-Party Businesses”), including for monetary or other compensation. You will have discretion in determining the items of Shelf Account Information that are shared with such Third-Party Business. You agree and acknowledge that the Third-Party Business is unaffiliated with Shelf and that the Third-Party Business’ use and processing of your personal information will be done in accordance with their respective Privacy Policies. If you have questions or concerns regarding a Third-Party Business’ processing of your information or would like to exercise any rights that you may have with respect to information processed by a Third-Party Business, please contact the corresponding Third-Party Business.

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‍Privacy Choices

You have the following choices regarding our collection and use of your personal information:

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Access or update your Shelf Account Information. You may review and update your Shelf Account Information by logging into your account.

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Opt-out of marketing communications. You can opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the emails you receive from us. If you do so, you will continue to receive service-related and other non-marketing emails until you cease using our services linked to those service updates.

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Privacy rights. You have the right to submit requests about your personal information, depending on your location and the nature of your interactions with our services, for:

• Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.

• Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.

• Correction of personal information that is inaccurate or out of date.

• Deletion of personal information that we no longer need to provide our services or for other lawful purposes.

• Additional rights, such as to object to and request that we restrict our use of your personal information, and where applicable, to withdraw your consent.

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To make a request, please email us as provided in the “Contact Us” section below. We may ask for specific information from you to help us confirm your identity. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

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Online tracking opt-out. There are a number of ways to opt out of having your online activity and device data collected through our Services, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org.
  
  Use the following links to learn more about how to control cookies and online tracking through your browser:
  Firefox; Chrome; Microsoft Edge; Safari

• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

• Google Analytics. We use Google Analytics to help us better understand how people engage with the Services by collecting information and creating reports about how users use our Services. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout. 

• Using privacy plug-ins or browsers. You can block our Services from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third-party cookies/trackers.

• Platform opt-outs. Some third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, allow you to opt-out directly by using their opt-out tools. Some of these providers, and links to their opt-out tools, are:
  Google 
  Facebook

• Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
  Digital Advertising Alliance 
  Network Advertising Initiative

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Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

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Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “Contact Us” section below.

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Do Not Track. Some Internet browsers can be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Third-Party Services

Our website and services can contain links to websites and other online services operated by third parties. In addition, our content can be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of or representation that we are affiliated with any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Information Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of personal information.

Children’s Privacy

Our services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through our services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

Retention

We retain your personal information for as long as appropriate to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we process personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Cross-Border Processing of Personal Information 

Please note that we are headquartered in the United States. To provide and operate our services, it is necessary for us to process your personal information in the United States. 

If we transfer personal information across borders such that we are required to apply appropriate safeguards to personal information under applicable data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you, for example through posting the Privacy Policy on our services. 

Contact Us

support@koodos.com
Koodos Inc,
515 Greenwich Street,
New York,
NY.
10013.