Privacy Policy

This Privacy Policy for Shift Technologies Inc. (“Shift”, “we”, “us”, or “our”) describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you (“User” or “you”) interact with us, including when you: (1) visit or interact with our website at getflashlightlauncher.com, or any website of ours that links to this Privacy Policy; (2) download, install, or use Flashlight Magnifier Launcher, or any mobile application of ours that links to this Privacy Policy (each, the “App”); and/or (3) engage with us in other related ways, including when you contact us for support or submit feedback (collectively, "Services"). “Personal information” means any information relating to an identified or identifiable natural person, as defined by applicable privacy or data protection laws.

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services and uninstall the App. If you still have any questions or concerns, please contact us at privacy@getflashlightlauncher.com.

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you voluntarily provide to us.

We collect personal information that you voluntarily provide to us when you contact us for support or submit feedback about the Services.

Personal information provided by you. The personal information that we collect depends on the context of your interactions with us and the Services. The personal information we collect may include the following:

email addresses (if you contact us for support)
any other information you choose to provide when contacting us

Information automatically collected

In Short: Some information, such as your Internet Protocol (IP) address and/or device characteristics, is automatically collected when you use our Services.

We automatically collect certain information when you use the Services. This information may include device and usage information, such as your IP address, device characteristics, operating system, country, approximate location (derived from your IP address), information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, to provide features, and for our internal analytics, advertising, and reporting purposes.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information we automatically collect when you access or use our Services. Depending on how you interact with us, this log data may include your IP address, device information, information about your activity in the Services (such as the date/time stamps associated with your usage, app screens viewed, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash logs"), and hardware settings).
Device Data. We collect device data such as information about your device you use to access the Services. This device data may include information such as your IP address, device and application identification numbers, advertising ID, app set ID, hardware model, mobile carrier, operating system, and app version. We also collect install referrer data to understand how you discovered the App.
Location Data. We collect approximate location information derived from your IP address (such as your city or region). We do not request access to your device’s GPS or precise location services.

Sensitive personal information. We do not collect or process sensitive personal information as defined under applicable privacy laws.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, deliver advertising, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for the following purposes:

To support and improve our Services. We may process your information to operate and maintain the App, deliver content and features (including advertisements), analyze usage trends, and improve the user experience.
To deliver personalized advertising. We and our advertising partners may process your information, including your advertising ID, to show you advertisements that may be more relevant to your interests.
To respond to user inquiries/offer support. We may process your information to respond to your inquiries and solve any potential issues you might have with our Services.
To comply with law. We may process your information where we believe it is necessary to comply with applicable laws or legal obligations.

4. Do we use tracking technologies?

In Short: We may use tracking technologies to support analytics and advertising.

We may use software development kits, device identifiers such as your advertising ID, and similar technologies to gather information when you interact with our Services. Some tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic App functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, and to tailor advertisements to your interests. The third parties and service providers use their technology to provide advertising tailored to your interests, which may appear in the App or on other apps or websites.

To the extent these online tracking technologies are deemed to be a “sale”/”sharing” (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by resetting or deleting your advertising ID in your device settings, submitting our Do Not Share My Personal Information form at getflashlightlauncher.com/ccpa-form, the links below, or submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE ADDITIONAL PRIVACY RIGHTS?"

AccuWeather

We may share your information with AccuWeather to provide weather information through the App. AccuWeather’s services help us provide weather information based on your approximate location. For more information on AccuWeather’s privacy practices, please visit the AccuWeather Privacy Policy at https://www.accuweather.com/en/privacy.

AppsFlyer

We may share your information with AppsFlyer to track and analyze the use of our Services. AppsFlyer’s services assist us in measuring the performance of our applications and marketing campaigns. To opt out of being tracked by AppsFlyer, visit https://www.appsflyer.com/legal/opt-out/. For more information on the privacy practices of AppsFlyer, please visit the AppsFlyer Services Privacy Policy at https://www.appsflyer.com/legal/services-privacy-policy.

Firebase

We may share your information with Firebase to track and analyze the use of the Services and to monitor App stability. Firebase Analytics and Crashlytics provide insights that help us improve our App’s performance and user engagement. For more information on the privacy practices of Firebase, please visit Firebase’s Privacy and Security portal at https://firebase.google.com/support/privacy.

Google AdMob

We may share your information with Google AdMob to display advertisements, including personalized advertisements, and measure advertising performance within the App. For more information on Google’s privacy practices, please visit the Google Privacy Policy at https://policies.google.com/privacy.

Mixpanel

We may share your information with Mixpanel to track and analyze the use of our Services. Mixpanel’s services help us understand how users interact with our Services so that we can improve functionality and user experience. For more information on Mixpanel’s privacy practices, please visit the Mixpanel Privacy Statement at https://mixpanel.com/legal/privacy-policy.

Yahoo

We may share your search queries with Yahoo to provide search functionality and search results through the App. For more information on Yahoo’s privacy practices, please visit the Yahoo Privacy Policy at https://legal.yahoo.com/us/en/yahoo/privacy/index.html.

5. Is your information transferred internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in various regions around the world, including, but not limited to, Canada (where our headquarters are located). If you are accessing our Services from outside, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in Canada, the United States, and other countries. Please note that the privacy laws and other laws of countries to which your information may be transferred might not be as comprehensive as those in your country. We take appropriate measures, in compliance with applicable law, to ensure that your personal information remains protected.

6. How long do we keep your information?

In Short: 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). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, 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.

7. How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to individuals under 18 years of age.

We do not knowingly collect, solicit data from, or market to individuals under 18 years of age, nor do we knowingly sell or share such personal information. By using the Services, you represent that you are at least 18 years of age. If we learn that personal information from users under 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from individuals under 18 years of age, please contact us at privacy@getflashlightlauncher.com.

9. What are your privacy rights?

In Short: We will consider and act upon any privacy request in accordance with applicable privacy laws. Based on the applicable laws of your state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Advertising ID

You can reset or delete your advertising ID at any time in your device settings. Learn more about our tracking technologies in the section "DO WE USE TRACKING TECHNOLOGIES?"

10. Do United States residents have additional privacy rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, or other state with a consumer privacy law, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

Categories of personal information we collect, with examples and whether each is collected.
Category	Examples	Collected
A. Identifiers	Internet Protocol address; device or app identifiers, such as advertising ID, device ID, app set ID, and install referrer; and email address (if you contact us)	YES
B. Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	NO
C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	App interactions, such as screens viewed, features used, and other in-app activity; crash logs and diagnostics; and ad interactions	YES
G. Geolocation data	Approximate location (city or region inferred from IP address)	YES
H. Audio, electronic, sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	NO
J. Education Information	Student records and directory information	NO
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	NO
L. Sensitive personal information	Precise geolocation, race, religion, sexual orientation, health, biometrics, citizenship	NO

We may also collect other personal information that you choose to provide when you contact us, including when:

You request help through our customer support channels; or
You submit feedback or otherwise communicate with us about the Services.

Sources of Personal Information

Learn more about the sources of personal information we collect in the section, "WHAT INFORMATION DO WE COLLECT?"

How We Use Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

How Long We Retain Personal Information

Learn more about how long we retain personal information in the section, "HOW LONG DO WE KEEP YOUR INFORMATION?"

Your Rights

You have rights under certain US state privacy laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

Right to know whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to non-discrimination for exercising your rights
Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

Right to access the categories of personal data being processed
Right to obtain a list of the categories of third parties to which we have disclosed personal data
Right to obtain a list of specific third parties to which we have disclosed personal data
Right to review, understand, question, and correct how personal data has been profiled
Right to limit use and disclosure of sensitive personal data
Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature

How to Exercise Your Rights

To exercise these rights, you can submit a request through our Do Not Share My Personal Information form at getflashlightlauncher.com/ccpa-form, contact us by emailing us at privacy@getflashlightlauncher.com, or refer to the contact details at the bottom of this document.

Under certain US state privacy laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state privacy laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@getflashlightlauncher.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?"

Do Not Share My Personal Information form

11. What controls do we have for Do-Not-Track and Global Privacy Control signals?

In Short: We do not currently respond to DNT browser signals but do honor GPC browser signals.

Do-Not-Track (DNT)

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals. California law requires us to let you know how we respond to web browser DNT signals. Because there is currently no industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

Global Privacy Control (GPC)

To manage cookies related to browser-based requests to getflashlightlauncher.com, you can make your preference known using the Global Privacy Control ("GPC") signal. Requests sent using the Global Privacy Control will apply to the referenced website that you visit on the device and/or browser from which they are submitted. For more information about the Global Privacy Control, please visit https://globalprivacycontrol.org/.

12. Do we make updates to this Privacy Policy?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

13. How can you contact us about this Privacy Policy?

If you have questions or comments about this policy, you may contact our privacy officer by email at privacy@getflashlightlauncher.com or contact us by mail at:

Shift Technologies Inc.
Attn: Privacy
520-1515 Douglas Street
Victoria, BC, V8W 2G4
Canada