Privacy Policy



Last update: August7 2020

1. General

This Privacy Policy (together with our Terms of inSharerance) governs collection, processing and use of our Participants' and visitors of our Sites' Personal Information.

Please find below some basic definitions which may help you to understand this Privacy Policy: Participant(s): people who participate in inSharerance. “You” and “Your” can be used as Participant(s) and Participant(s)’s.
Administrator: inSharerance system administrator; inSharerance LLC of 919 North Market Street, Suite 950, Wilmington, DE 19801 USA including but not limited to, its members, managers, officers, employees, agents or other related parties, unless otherwise provided herein. “We”, “Us” and “Our” can be used as meaning of “Administrator and/or inSharerance” and “Administrator’s and/or inSharerance’s”.
Data Subject: an identified or identifiable person (Participant).
Data Controller: a company which determines purposes and means of personal data processing.
Data Processor: a company which processes personal data on behalf and upon instructions of the Data controller.
Personal Data Processing: any operation or set of operations performed on personal data (e.g., collection, storage, use, disclosure, erasure).

Other capitalized terms, not defined above, have the meanings as defined in the Terms of inSharerance.

The purpose of this Privacy Policy is to inform you of:


2. Gathering and Use of Personal Information

We may collect your Personal Information if you participate inSharerance and open an Account to participate the Platform or perform any Transactions on the Platform. This is defined as collection for the purpose of provision of service(s) to you in accordance with our Terms of inSharerance. Please note that if you refuse to share your Personal Information for this purpose, we will not be able to provide our services to you.

The types of Personal Information which we collect may include:

We will process your Personal Information only for the purpose(s) of providing to you the service(s) that you ask us to provide you, to satisfy the legal obligations stemming from regulatory obligations that arise from providing you the service(s) and our legitimate interest.

Based on our legal obligations and legitimate interest we may request other documents for your identity verification and the sources of your funds confirmation for the purposes of money laundering and fraud prevention.

We may use your Personal Information for the following purposes:


3. Children's Personal Data

Please take note inSharerance is exclusively offered to individuals at least 18 years old. We do not process any Personal Information of children under this age.


4. IP Addresses

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns and will not be used to identify any individual unless that same individual.


5. Cookies

We use a browser feature known as a "cookie", which assigns a unique identification to your computer. Cookies are typically stored on your computer's hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Sites, analyze trends, and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our Sites are most visited and difficulties our visitors may experience in accessing our Sites. With this knowledge, we can improve the quality of your experience on the Platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receipt of, and response to, our emails and to provide you with a more personalized experience when using our Sites.

We use third party service provider(s), to assist us in better understanding the use of our Sites. Our service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our Sites, what products are browsed, and general Transaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors' interests in our Sites and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the Platform. Our service provider(s) is/are contractually restricted from using information they receive from our Sites other than to assist us.

By using our Sites you are agreeing that we may use cookies for the purposes set out above.


6. Disclosure of Personal Information

We use the Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law.

We may make available the Personal Information that you provide to us for the limited purpose indicated for and during the provision of the service that you would have requested in particular to:

We may also share Users’ Personal Information with financial institutions, insurance companies or other companies in the case of a merger, divestiture, or other corporate re-organization and notify you of such sharing of your information to be able to exercise any of your rights where applicable.

We may also share Your Personal Information with law enforcement or regulatory agencies, as may be required by law. In certain cases, we may not be able to inform you of such sharing of data due to legal restrictions.

Any third party which receives or has access to Personal Information shall be required by us to protect such Personal Information and to use it only to carry out the services they are performing for you or for us, unless otherwise required or permitted by law. Such a third party, except for regulatory authorities, would be contractually bound to adhere to the same security and confidentiality policies as us and assume the same responsibilities as us.

The legitimate exercise of any of your rights with us will also be notified to be applied by any such third parties having been given access to your Personal Information.

We will ensure that any such third party is aware of our obligations under this Privacy Policy and we will enter into contracts with such third parties by which they are bound by terms no less protective of any Personal Information disclosed to them than the obligations we undertake to you under this Privacy Policy or which are imposed on us under applicable data protection laws.


7. International Data Transfers

Our contractors and affiliates are situated at different locations (including countries located outside the USA) and we sometimes need to transfer your personal data to third countries to provide our services to you. We strive to ensure adequate level of your personal data protection wherever our contractor is located. Be sure we may transfer your Personal Information only in the following cases:


8. Your Rights

You have the right to access your Personal Information and to require the correction, updating and blocking of inaccurate and/or incorrect data by contacting us.

Upon your written request, we will inform you of the Personal Information relating to you that we hold and the use and general disclosure of your Personal Information. We will also give you a copy of the Personal Information we have retained. There may be a minimal charge for providing you additional copies of your Personal Information to cover administrative costs.

You may also request the deletion or destruction of both the Account and Personal Information by contacting us. We will action your request immediately, except, where this is not consistent with its legal and regulatory obligations.

To ensure the confidentiality, integrity and availability of your information to yourself, we may request you to confirm your identity by providing identification documentation and/or other methods prior to assisting you in exercising any of your rights.

If you refuse to prove your identity, we may decline to take actions in respect of your data, save restricting processing, until we can ensure that such actions are the true wish of the data subject.

In the carrying out of our services we may use automated processing and profiling to reduce the risks of fraud, money laundering and abuse of our services. Through this automated processing, we carry out an analysis of your identification, transactional and behavioral patterns.


9. Security

We have implemented technical and organizational security measures to ensure the confidentiality, integrity and accountability of your Personal Information and to protect your Personal Information from loss, misuse, alteration or destruction. Such measures include:

Only authorized personnel of us have access to your Personal Information, and these personnel are required to treat the information as confidential.

Where you have consented to, or we are obliged to pass on Personal Information to third parties to provide you with a requested service or in the carrying out of a regulatory or legal obligation, we will request that the same levels of technical and organizational security measure be applied through contractual arrangements, where possible.

We conduct testing, assessment and evaluation of our technical and organizational measures effectiveness on a regular basis. Technical and organizational security measures in place will, from time to time, be reviewed in line with legal and technical developments.

In the event of a personal data breach or the failure of the measures of protection of such information we will immediately notify you without undue delay.


10. Links

There may be links from our Sites to other sites and resources provided by third parties. This Privacy Policy applies only to our Sites. Accessing those third-party sites or sources requires you to leave our Sites.

We do not control those third party sites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit.


11. Retention of Personal Information

Your information is held within Amazon Web Services (AWS) cloud. Access to this information is provided to employees of us whose office may also be outside of U.S.A. but who adhere to the same principles of data security and processes.

Your payment method information that you may use to effect or receive payments from us are passed on to a third-party payment processor(s) and with which we have a contractual agreement to safeguard your rights. Unless you create an account with us and conduct transactions, we do not retain your payment method information.

We will hold your Personal Information only for as long as it is necessary for the purposes described in this Privacy Policy and our own legal and regulatory requirements.

In accordance with record keeping activities for Anti-Money Laundering, Tax and Company legal obligations and considering the period during which you may bring legal claims against us under the law of Delaware U.S.A., we will retain Personal Information for a period of five years after our User closes his or her Account and terminates legal relationships with us for five years from the end of the tax period in which the User conducts his or her last transaction.

Data stored for regulatory purposes only will be protected from unnecessary processing and will be held only for the purpose of being able to provide information or access to relevant authorities.


12. Disposal of Personal Information

Once we do not have any obligation to providing you with a service you requested, nor an obligation to hold Personal Information for regulatory or legal purpose, we will anonymize or dispose of your Personal Information in line with acceptable industry and security standards so that this cannot be subsequently retrieved and associated to you.

Where we cannot directly remove such records, such as in archived backups, we will retain a log of which Personal Information should be removed if ever the backup data is restored.


13. Marketing

We will ask you for your consent on registration or post-registration to allow us to contact you or use your Personal Information for marketing purposes. We may also notify our existing Users on our own products or services similar to those we have already provided based on our legitimate interest.

You have the right to retract the consent for us to process your Personal Information for marketing purposes. You can exercise your right to prevent such processing by contacting us.

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