Privacy Policy
Shine Guards Privacy Policy
At Shine Guards, we take data protection very seriously. Data protection and information security are at the heart of Shine Guards. This privacy policy describes the key principles and practices we follow to ensure that your privacy is respected when you use our services.
Shine Guards e.U. ("Shine Guards", "we") processes personal data of users of Shine Guards cleaning and other home-related services ordered via the website, of users of other Shine Guards services, and of visitors to the website shineguards.com ("Website").
In this privacy policy, the term "Shine Guards Services" refers to the Website and to other services Shine Guards provides to users. "User" or "you" means our customers and the customers of our companies, users of Shine Guards cleaning services, representatives and other authorised users of our customer organisations, prospective customers and users of Shine Guards Services. This privacy policy explains, among other things, which types of personal data we process, how we process them, and how you can exercise your rights as a data subject (for example the right to object and the right of access).
For some of our services we may provide a separate privacy policy. If a particular service has its own privacy policy, we will make that known in connection with that service.
This privacy policy may be updated from time to time to reflect changes in our data-processing practices or other changes. The current version is available on the Website. We will not make material changes to this privacy policy or restrict users’ rights under it without notifying you.
1. CONTROLLER(S) OF THE PROCESSING
This privacy policy applies to the processing of personal data carried out by Shine Guards.
With regard to the processing of personal data of users in Austria, Shine Guards e.U., Stoß im Himmel 1/21, 1010 Vienna, Austria (company register number: FN 632715 p) acts as (joint) controller.
Shine Guards e.U. is responsible for handling all enquiries and questions relating to the processing of personal data.
2. SHINE GUARDS CONTACT DETAILS
Shine Guards e.U.,
Correspondence address: Stoß im Himmel 1/21, 1010 Vienna, Austria
E-mail address: hello@shineguards.com
3. PERSONAL DATA PROCESSED AND DATA SOURCES
We process personal data only to the extent necessary and appropriate for the respective processing purpose. The personal data we collect and process can be divided into two general categories: user data and usage data.
User data
User data is personal data collected directly from you or from our customer organisation on whose behalf you use Shine Guards Services ("customer organisation"). We may collect user data from our users and customer organisations in various ways, for example after concluding a service contract with the customer organisation, or when users register for Shine Guards Services, subscribe to a newsletter or fill in a form. Please also note that we record details of all transactions and payments you make via Shine Guards Services.
User data required to use Shine Guards Services
The following personal data that we collect and process is required for the proper performance of the contract between you and us, for our legitimate interest in fulfilling our contractual obligations towards our customer organisations, and for compliance with our legal obligations.
After the service contract between us and the customer organisation is concluded, the customer organisation provides us with your full name and e-mail address.
If you register for Shine Guards Services and create a user account, you must provide us with the following information:
• Full name
• Phone number
• E-mail address
• Information about your means of payment, such as the number and expiry date of your payment instruments (required for ordering goods and other products via Shine Guards Services; these details are not stored by Shine Guards because a third-party payment provider processes the payments)
User data that you provide voluntarily while using Shine Guards Services
Your user or customer experience can be improved if you provide us with the following information:
Additional account information:
• Photo
• Delivery address
• Location data (if you consent to the processing of your location data)
• Partner-specific bonus card or participation in another loyalty programme, if applicable in your country
• when ordering age-restricted goods: age, and
• other information you provide when creating a user account or later when changing your account profile.
Other information
We may also process other information that you provide to us voluntarily, such as:
• Information relating to your orders with Shine Guards or via Shine Guards Services (for example purchased items, special instructions, date and time of the order, total amount and other order history)
• Information you provide when submitting reviews, comments or taking part in surveys
• Preferred restaurants or retailers and other preferences
• Marketing opt-ins and opt-outs, and
• Information you provide to us by phone, e-mail or chat, including recordings of your calls to our customer service
In addition to the user data collected from you and the customer organisation, we process certain personal data provided about you by third parties. For business customers, for example, we may process information about the company’s contact person in order to enable communication and marketing with the company and to manage the customer relationship. Such data comes primarily from public sources such as local commercial registers, companies that offer this type of information service, or the companies themselves.
Where required by applicable law, Shine Guards will obtain a separate consent for the processing of this personal data. You may withdraw this consent at any time via your profile settings or by contacting Shine Guards support at hello@shineguards.com.
If you connect your account with Facebook or sign in there, Facebook shares personal information about you with us, such as your profile picture, a selection of your Facebook friends and your Facebook ID. While Shine Guards maintains its page on Facebook, Shine Guards and Facebook are joint controllers of your personal data. Further information about the processing of personal data on Facebook is available in the Meta privacy policy.
Usage data
Usage data arises from users’ interaction with Shine Guards Services. Although we do not usually use usage data to identify you as an individual, in certain circumstances you may be identifiable from this data alone or in combination with user data. In such cases usage data may also be personal data under applicable law, and we will treat it as personal data.
Cookies and other technologies
We use various technologies to collect and store usage data and other information when users visit Shine Guards Services, including cookies, website data storage and web and application telemetry.
Cookies and other website data stored on your device allow us to identify visitors to Shine Guards Services, make use of the services easier and compile aggregated information about our visitors. This helps us improve Shine Guards Services and offer our users a better service. Cookies and other website data do not harm your device or files. We use them to tailor Shine Guards Services and the information we provide to users’ individual interests. Please note that although the retention period of the various cookies is limited, it can range from less than a minute to periods that cannot be determined in advance until a particular cookie is deleted.
Users can set their web browser to refuse cookies. The following links explain how to adjust cookie and other web-data settings in some common browsers:
• Apple Safari
• Google Chrome
• Microsoft Edge
• Mozilla Firefox
Please note that some parts of Shine Guards Services may not work properly if cookies are refused.
Shine Guards Services use pseudonymised identifiers to track and predict your app and service usage and your preferences. Shine Guards also uses session-related third-party tracking technologies to verify and report transactions initiated by our advertising partners.
You can manage your cookie settings via the cookie banner on our websites.
Shine Guards uses various third-party providers of analytics and telemetry data, marketing or affiliate partners and other services integrated into our customer software (see below):
Name
Provider
Purpose
Provider’s privacy policy
Google Analytics
Visitor and usage analytics
Link
Google AdSense
Ad targeting
Link
Google Tag Manager
Analytics and reporting
Link
Facebook Graph API
Meta
Ad management
Link
Facebook Pixel
Meta
Advertising / conversion tracking
Link
Please note that not all of the providers listed above are necessarily in use at all times or in all markets.
4. PURPOSES AND LEGAL BASES OF PROCESSING
We process personal data only to the extent necessary and appropriate for the respective processing purposes. Please note that one or more of the following purposes and legal bases may apply at the same time.
First, Shine Guards processes your personal data to fulfil our contractual obligations towards you or the customer organisation, for example to the extent necessary to:
• provide you with Shine Guards Services in accordance with the contract between you and Shine Guards, or between the customer organisation and Shine Guards, or between the Shine Guards Drive customer and Shine Guards;
• perform the contract between you and Shine Guards, manage and deliver your order, and communicate with you about changes to the terms and conditions, privacy policies or other important contract-related changes;
• process your payments or any refunds (where applicable) and provide our partners (restaurants, retailers and courier partners, together also “partners”) with the information needed to prepare or deliver your order; and
• answer your questions or resolve your support cases when you contact us.
Second, we may process your personal data where there is an appropriate and justified interest (i.e. a legitimate interest) in running, maintaining and developing our business or in building and maintaining customer relationships. When we decide to use your data on the basis of our legitimate interests, we balance our interests against your right to privacy, for example by offering an easy way to opt out of marketing communications and by using pseudonymised or non-personally identifiable data where possible. You have the right to object to processing based on legitimate interest. Shine Guards may, however, refuse such an objection under applicable law, for example where processing is necessary to prepare, exercise or defend legal claims.
We process your personal data, where necessary and on the basis of a legitimate interest, for example:
• for claims handling, debt collection and legal proceedings. We may also process data to prevent fraud, misuse of our services and for information, system and network security;
• to contact you about Shine Guards Services, inform you of related changes, or ask for your rating or feedback on Shine Guards Services;
• to market Shine Guards Services to you, show you targeted or personalised advertising about Shine Guards Services, or otherwise send you targeted marketing for services or products that may interest you. To create such a tailored offer we may process the information listed above in the usage-data section. Please note that processing of personal data for marketing purposes is based on your consent where required by applicable law (see also the “Direct marketing” section below);
• to improve the quality of Shine Guards Services and further develop our business, for example by analysing usage trends through processing data about your use of Shine Guards Services;
• to ensure that our services meet your needs, personal data may be used, for example, for customer-satisfaction surveys. Where possible we use only aggregated, non-personally identifiable data for this; and
• to process your data within the Shine Guards group in accordance with this privacy policy.
5. TRANSFERS TO NON-EUROPEAN COUNTRIES
We will take measures to ensure that users’ personal data receive an adequate level of protection in the countries where they are processed. We provide appropriate and sufficient protection for transfers of personal data to countries outside the European Economic Area through agreements with our service providers based on Standard Contractual Clauses or through other appropriate safeguards.
Further information about transfers of personal data is available if you contact us at one of the addresses above.
6. DATA RECIPIENTS
We do not disclose your personal data to other organisations.
7. RETENTION PERIOD
Shine Guards does not store your personal data longer than is legally permitted and necessary to provide Shine Guards Services or the relevant parts of them. The retention period depends on the type of information and the purposes of processing. The maximum period may therefore vary depending on use.
After the user has deleted their user account, personal data may only be stored for as long as such processing is required by law or necessary for our legal obligations or legitimate interests, such as handling claims, accounting, internal reporting and reconciliation.
We regularly review the retention period of personal data to ensure that data is stored only for as long as necessary.
8. YOUR RIGHTS
Right of access
You have the right to access the personal data we process about you and to be informed about it. We give you the option to view certain data via your user account in Shine Guards Services or to request a copy of your personal data by contacting us.
Right to withdraw consent
If processing is based on consent given by the user, the user may withdraw that consent at any time free of charge. Withdrawal of consent may mean that the ability to use Shine Guards Services is limited. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectification
You have the right to have inaccurate or incomplete personal data we store about you rectified or completed by contacting us. You can correct or update some of your personal data via your user account in Shine Guards Services.
Right to erasure
You may also ask us to delete your personal data from our systems. We will comply with such a request unless we have a legitimate reason not to delete the data.
Right to object
You have the right to object to a particular use of your personal data where those data are processed to pursue our legitimate interest. If you object to further processing of your personal data, this may limit your ability to use Shine Guards Services.
Right to restriction of processing
You may ask us to restrict the processing of personal data, for example while your requests for erasure, rectification or objection are pending and/or if we have no legitimate grounds to process your data. This may, however, mean that you have fewer options to use Shine Guards Services.
Right to data portability
You have the right to receive the personal data you have provided to us in a structured, commonly used format and to transmit those data yourself to a third party.
How to exercise your rights
You can exercise the rights above by contacting Shine Guards support or by sending us a letter or e-mail to the addresses above, including your full name, address, e-mail address and a phone number. If you have a Shine Guards account, we recommend contacting us via Shine Guards support, as this makes it easier to identify you. We may request additional information needed to confirm the user’s identity. We may refuse or charge for requests that are unreasonably repetitive, excessive or clearly unfounded.
9. USE OF COOKIES
We use cookies on this website for the purpose stated above.
More information about the cookies used is available in the cookie banner, which you can open again at any time via the “Cookie settings” link in the footer of our website. Clicking the individual cookie categories and the “Show cookies” button shows details of all cookies used.
If you consent to data processing by cookies in our cookie banner, we collect statistical data using the “Google Analytics” tool to analyse how you use our website and parts of it and how you interact with our website.
Statistical data is collected on the basis of unique user IDs stored in cookies, your truncated IP address and other metadata about your device and browser.
For this purpose the data is also transferred to Google Ireland Ltd., based in Ireland, and Google will not store your IP address. Even though Google primarily stores the collected data in the EU, a transfer to Google LLC in the USA is possible. Google LLC is certified under the EU-U.S. Data Privacy Framework and therefore also guarantees an adequate level of data protection in the USA pursuant to Article 45 GDPR.
We use the statistical data collected in this way to understand how our website is used and to make our website offering as attractive as possible for you. We will process and store this data only in aggregated form; all non-aggregated data collected in this way is deleted or anonymised immediately after aggregation.
If you give your consent in the cookie banner, we also use the statistical data collected in this way for marketing purposes and pass it on to our advertising partners to measure the reach of our advertising. More information about our advertising partners is available directly in the cookie banner.
We also use functional cookies on the website. These help us improve your experience, for example by ensuring that certain pop-ups are not shown too often.
In the cookie banner you can also choose to consent only to cookies for individual processing purposes (statistics cookies, marketing cookies, functional cookies).
This cookie-related data processing is based on the consent you gave in the cookie banner (Art. 6(1)(a) GDPR, § 165(3) TKG 2021). This consent is voluntary and not required to use our website. You can withdraw or change this consent at any time by clicking the “Cookie settings” link in the footer, which reopens the cookie banner so you can refuse cookie processing, or by deleting our website’s cookies in your browser.
10. LODGING A COMPLAINT
If the user believes that our processing of personal data is not compatible with applicable data-protection laws, they may lodge a complaint with the local data-protection supervisory authority in Austria, the Datenschutzbehörde https://www.dsb.gv.at/. Alternatively, the user may lodge a complaint with another local and competent data-protection supervisory authority.
11. INFORMATION SECURITY
We use administrative, organisational, technical and physical safeguards to protect the personal data we collect and process. Measures include, for example, encryption, pseudonymisation, firewalls, secure facilities and access-control systems where appropriate. Our security controls are designed to ensure an appropriate level of data confidentiality, integrity, availability, resilience and recoverability. We regularly test Shine Guards Services, systems and other facilities for security vulnerabilities. In addition, Shine Guards employees’ access to personal data is restricted to what is required for their job duties.