Privacy Policy
Effective Date: October 16, 2018

The EasyShift website (www.EasyShiftApp.com, “Site”), mobile application (“App”) and related services (collectively – the “Services”) are operated and provided by Quri, Inc. (“Quri”, “we”, “us” and/or “our”).

We respect the privacy of our visitors and users and are strongly committed to making our practices regarding your data more transparent and fair. This Privacy Policy describes how we collect, store, use and disclose your personal data, and it applies whenever you visit our Site, install our App and access or use any of our Services.

Specifically, it describes our practices and policy regarding –

  1. Data Collection
  2. Data Uses
  3. Data Location and Retention
  4. Data Sharing
  5. Cookies and Tracking Technologies
  6. Communications
  7. Data Security
  8. Data Subject Rights
  9. Children's Privacy
  10. Additional Notices

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please discontinue and avoid using our Services.

You are not legally required to provide us with any Personal Data (defined below), but without it we will not be able to provide you with the full range of Services or with the best user experience when using our Services.

1. Data Collection

We collect Personal Data regarding users of our App as well as data regarding visitors to our Site. Such data is typically collected and generated through the visitor's or user's interaction with our Services, through automatic means or directly from our visitors or users.

Specifically, we collect the following categories of data (which, if it could be used to identify a specific person, or is linked to such identifying data, will be deemed as "Personal Data"):

1. Data Automatically Collected or Generated: When you visit, interact with or use our Services, we may collect or generate certain technical data about you. We collect or generate such data either independently or with the help of third party services (as detailed in Section 4 below), including through the use of "cookies" and other tracking technologies (as further detailed in Section 5 below).

Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, non-identifying data regarding a device, operating system, browser version, locale and language settings used, the cookies and pixels installed on such a device and the activity (clicks and other interactions) of visitors and users in connection with our Services. Such data does not enable us to learn a person's true identity or contact details. We mainly use such data gain a better understanding of how users typically use our Services and how we can improve their user experience, and to optimize our marketing campaigns and ad management, as well as the overall performance of our Services.

2. Data Received From You: You may provide us with Personal Data when registering to use and using our Services, such as your name, geolocation, contact details (such as e-mail, phone and address), account login details (such as username and hashed passwords) (the latter collectively "Account Data"), as well as any other data and content you choose to provide when you use our Services, interact with us by creating a user account, when contacting us or when interacting with other users or parties through our Services. Users that have subscribed to our App may provide us additional Account Data such as their PayPal accounts, for payment purposes. To the extent that such Account Data concerns a non-human entity (e.g. the bank account of a company or business), we will not regard it as “Personal Data” and this Privacy Policy shall not apply to it.

3. Customer Feedback: Our customers (for whom you may perform tasks and shifts while using our App and Services) may also provide us with data concerning you, such as their feedback concerning your performance of such tasks and shifts.

4. Data in Content: Our App and Services may be used in order to capture and upload images, typically images of in-store or in-venue shelves holding stock and products, or other forms of content (such as responses to questionnaires or forum posts). All users are instructed to only submit to us such content which does not in any way contain any Personal Data of any individuals whatsoever. All users are also instructed not to submit or upload photographs of any person(s).

5. Data About Locations: Our Services may also collect and use your location information (for example, by using the GPS on your mobile device) to provide certain functionality of our Services (for example, to verify that you have performed the shift in the correct location).

2. Data Uses

We use your Personal Data as necessary for the performance of our Services; for complying with applicable law; and based on our legitimate interests in maintaining and improving our Services, understanding how our Services are used, optimizing our marketing, customer service and support operations, and in order to protect and secure our users, customers, ourselves and our Services.

Specifically, we use Personal Data for the following purposes:

  1. To facilitate, operate, and provide our Services;
  2. To authenticate the identity of our users, and to allow them access to our Services;
  3. To provide our visitors and users with assistance and support;
  4. To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties;
  5. To contact our users, with general or personalized service-related messages (such as password-retrieval or billing); to contact our users with promotional messages (such as newsletters, new features etc.); and to facilitate, sponsor and offer certain events and promotions;
  6. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
  7. To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
  8. To comply with any applicable laws and regulations.

3. Data Location and Retention

Data Location: Your Personal Data may be maintained, processed and stored by Quri, and its affiliates and Service Providers (defined below) in the United States of America, Europe and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.

Quri has applied to self-certify with the EU-US and Swiss-US Privacy Shield Frameworks, with respect to personal data it receives or processes which concerns individuals residing in the EU or Switzerland. We will update this section once our application is granted. All Personal Data received from European Union (EU) member countries and Switzerland will be processed in reliance on the applicable Privacy Shield Framework and in accordance with the Framework’s applicable principles. To learn more about the Privacy Shield Framework, please visit www.privacyshield.gov.

While privacy laws may vary between jurisdictions, Quri, and its affiliates and Service Providers are committed to protect Personal Data in accordance with this Privacy Policy and with customary industry standards, regardless of any lesser legal requirements that may apply.

Data Retention: We retain your Personal Data in order to maintain and expand our relationship, and to provide you with our Services. We will retain your Personal Data for as long as you remain our user, or for as long as your account is active and you have not notified us otherwise. We will also retain your Personal Data for legal, contractual and accounting purposes, and to protect ourselves from any potential disputes (i.e. as required by laws applicable to record and bookkeeping, as necessary for allowing the users you engaged with via our Services to meet their own obligations or legitimate needs, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.

Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by email at privacy@TraxRetail.com.

4. Data Sharing

Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, marketing and advertising services, data and cyber security services, payment processing services, user engagement services, e-mail distribution and monitoring services, session recording, and our business, legal and financial advisors) (collectively, "Service Providers"). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.

Facebook: We use Facebook’s Software Development Kit (SDK) in the App. The Facebook SDK is produced and administered by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. This SDK allows us to gain insight into which of the advertising campaigns run on Facebook has induced a user to download the App.

We share the following information with Facebook for this purpose: the App ID, App version, and information regarding launch of the App. We share no other data with Facebook. Additionally, individual user activities (events) may be analyzed from within the App, making it possible for us to better define target groups for our advertising campaigns. We receive an aggregated evaluation of App user behavior from Facebook. Beyond this, we have no influence on the information that is processed by Facebook via App events. Further information about the Facebook SDK may be found at https://developers.facebook.com/docs. Facebook’s privacy policy may be found at: https://www.facebook.com/about/privacy.

Sharing Personal Data with our Customers: We may share the Personal Data of users with our customers for whom such users perform shifts and tasks, as required in the context of such shifts and tasks.

Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Quri, any of our users or customers, or any members of the general public.

Quri Affiliated Companies: We may share Personal Data internally within our group of companies for the purposes described in this Privacy Policy. In addition, should Quri or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

Please note: Quri may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

5. Cookies and Tracking Technologies

Our Services and some of our Service Providers utilize "cookies", anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your experience as a user and monitor the performance of our activities and campaigns. A "cookie" is a small text file that is used, for example, to collect data about activity on our Site. Some cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by the user.

A list of the cookies we use is as follows:

Name Domain Type
Answers fabric.io event tracking
Crashlytics fabric.io crash logging
Segment segment.io event tracking
Facebook https://developers.facebook.com/docs/ios event tracking
Facebook https://developers.facebook.com/docs/android event tracking

How to Adjust Your Preferences Regarding Cookies and Interest-based Advertising

While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser and recommend their use for an optimal experience of our Services, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

If you wish to prevent the use of your mobile device's advertising ID, you may change your device settings to reset such advertising ID (typically, this is available under the "Privacy" or "Ads" section in your device settings). You may also change your browser settings to reset or block cookies (typically, this is available under the "Settings" or "Help" section in your browser menu).

6. Communications

Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, password-retrieval notices, etc. We, or our customers, may also send you notifications concerning shifts, messages and other updates. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.

Notifications and Promotional Communications: We may send you notifications concerning messages and other updates in your user account. We may also send you notifications about new features, offerings, events and special opportunities or any other information we think our users will find valuable. We may provide such notices through any of the contact means available to us (e.g. mobile push notifications or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify us at any time by sending an e-mail to privacy@TraxRetail.com or by following the "unsubscribe", "stop", "opt out", or "change e-mail preferences" instructions contained in each of the promotional communications you receive.

7. Data Security

In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption where appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.

8. Data Subject Rights

If you wish to exercise your rights under applicable laws to request access to, and rectification or erasure of your Personal Data held with us, or to receive a portable copy of such Personal Data – please contact us at privacy@TraxRetail.com. We will process such requests within thirty (30) business days. Please be advised that photographs, survey responses, and comments related to a Shift will not be provided in response to a request for access to, or a portable copy of your Personal Data.

Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request) in accordance with Section 3 above.

9. Children's Privacy

Our Services Are Not Designed to Attract Children Under the Age of 18. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 18 is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us regarding such child.

If you believe that we might have any such data, please contact us by email at privacy@TraxRetail.com.

10. Additional Notices

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Site and App. The amended version will be effective as of the date it is so published without notice to you. We will provide a 10-day prior notice if we believe any substantial changes are involved through any of the communication means available to us or via the Services. After this notice period, all amendments shall be deemed accepted by you.

External links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or application of such third parties and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.

Questions, Concerns or Complaints: If you have any comments or questions about this Privacy Policy or if you have any concerns regarding your privacy, please contact us by email at privacy@TraxRetail.com. Quri‘s Data Protection Officer may be contacted at dpo@TraxRetail.com.

Trax Retail Ltd. has been designated as Quri‘s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Trax Retail Ltd. can be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please contact privacy@TraxRetail.com. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.