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This Privacy Policy (“Policy“) governs the manner in which RGMS LLC (hereinafter referred to as “Company“, “we“, “us” or “our“) collects and further processes the personally identifiable information (“Personal Data“) you may provide on the sharpsheets.io website (“Website” or “Service“) and any of its related products and services (collectively, “Services“). It also describes the choices available to you regarding our use of your Personal Data and how you can access and update this information. This Policy is a legally binding agreement between you (“user“, “you” or “your“) and the Company. By accessing and using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Privacy Policy.

1. Content

  1. Categories of Personal Data collected
  2. Ways of Personal Data collection
  3. Personal Data use and processing: purposes and legal basis
  4. Cookies and automatic collection of information
  5. Direct marketing
  6. Third party service providers
  7. Disclosure of Personal Data
  8. International Personal Data transfer
  9. Your rights regarding your Personal Data
  10. GDPR Statement for the European Economic Area residents (“EEA residents”)
  11. Information security
  12. Retention of Personal Data
  13. Do no track signals
  14. Data breach
  15. Privacy of children
  16. Changes and amendments to our Privacy Policy
  17. Contacting us

2. Categories of Personal Data collected

You can access and use the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features on the Website, you may be asked to provide certain Personal Information. The categories of Personal Data that may be processed by, or on behalf of, the Company under this Privacy Policy (to the extent permitted by applicable laws) include:

  • personal details: name;
  • contact details: email address;
  • data relating to the Website: technical data (including device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to the Website, location data, and other technical communications information necessary for the operation of the Website); security login details; usage data; aggregate statistical information;
  • marketing data: cookie data; clickstream data; browsing history; responses to direct marketing; and opt-outs from direct marketing.

RGMS LLC does not seek to collect or otherwise process your sensitive personal data, except where:

  • the processing may be required or permitted by applicable laws;
  • the processing is necessary in order to establish, exercise or defend legal claims;
  • RGMS LLC has obtained your prior explicit consent before processing your sensitive personal data; or
  • any other lawful basis for processing your sensitive personal data.

You can choose not to provide us with your Personal Data, but then you may not be able to take advantage of some of the features on the Website. Users who are uncertain about what information is mandatory are welcome to contact us.

3. Ways of Personal Data collection

RGMS LLC may collect Personal Data from you in the following circumstances:

  • RGMS LLC may collect or obtain Personal Data when you visit the Website or use any features or resources available on or through the Website. When you visit the Website, your device and browser will automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, volume of data transferred, dates and times of connecting to the Website and other technical communications information) some or all of which may constitute Personal Data;
  • RGMS LLC may collect or obtain Personal Data when you download a preview of a template via the Website, specifically email address;
  • RGMS LLC may collect or obtain Personal Data when you purchase any Service provided by RGMS LLC via the Website, namely the following: name, email address, and if applicable, payment details;
  • RGMS LLC may collect or obtain Personal Data when you contact RGMS LLC (by mail, by email, or by any other means of communication).

4. Personal Data use and processing: purposes and legal bases

RGMS LLC collects and processes your personal information about you in a number of ways, including through your use of the Website. We have set out below the purposes for which we use your Personal Data and the legal basis (as set out in applicable data protection laws) that we rely on to justify this use of your information.

PurposeLegal Basis
Fulfill and manage ordersTo perform a contract between you and us
Deliver products or ServicesTo perform a contract between you and us
Enforce terms and conditions and policiesFor our legitimate business purposes ( provision of the Services) and, depending on the circumstances, to perform a contract between you and us
Measure interest in and improve our Services and productsFor our legitimate business purposes (provision and improvement of the Services)
Run and operate the Website and Services, audit and monitor the use of the WebsiteFor our legitimate business purposes (provision of the Services, as well as improvement and ensuring the security of those Services). We may request your consent in circumstances where a legal justification over and above legitimate interests is required by applicable law (in relation to the use of non-essential cookies)
Send administrative informationFor our legitimate business purposes (provision of the Services) and, depending on the circumstances, to perform a contract between you and us
Send marketing and promotional communicationsFor our legitimate business purposes (promotion of our products and services). We may request your consent in circumstances where a legal justification over and above legitimate interests is required by applicable law
To provide information requested by you and to respond to your communications, comments, queries and feedbackFor our legitimate business purposes (provision and support of our Services)
Request user feedbackYou have given your consent to this specific purpose
Post customers testimonialsYou have given your consent to this specific purpose
Improve user experiencesFor our legitimate business purposes (provision and improvement of our Services)
Notify you about special offers and products or services available from us or our partners that may be of interest to youFor our legitimate business purposes (promotion of our products and services). We may request your consent in circumstances where a legal justification over and above legitimate interests is required by applicable law
Resolve disputes or troubleshoot problemsFor our legitimate business purposes and for compliance with legal obligations to which we are subject
Prevent potentially prohibited or unlawful activitiesFor our legitimate business purposes and for compliance with legal obligations to which we are subject

Some information about you is required in order for us to provide you with relevant offerings from us and/or our partners and to enable you to enjoy other benefits of being our user.

4. Cookies and automatic collection of information

When you open the Website or access to our Services, our servers automatically record information that your browser sends. We use cookies and similar technologies to improve your experience and to enhance Website security. Cookies are small text files that are automatically placed on your device when you visit almost any website. They are stored by your internet browser and contain basic information about your internet use. This data may include information such as your device’s IP address, browser type and version, operating system type and version, language preferences or the webpage you were visiting before you came to the Website and Services, pages of the Website and Services that you visit, the time spent on those pages, information you search for on the Website, access times and dates, and other statistics. Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Website and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system. The cookies we use fall into three categories:

  • Strictly necessary (essential) cookies. These cookies are necessary to help you access and move around the Website and use all its features. Without these cookies, the Website would not work properly and you would not be able to use certain important features. For example, we use essential cookies for fraud detection and prevention purposes. You cannot turn off essential cookies through the Cookie Consent Tool, as such cookies are necessary for you to access and use the features of the Website.
  • Functionality cookies. These cookies allow the Website to remember your Website preferences and choices you make on the Website. This allows the Website to provide personalized features. They are anonymous and don’t track browsing activity across other websites. These cookies help us to remember your preferences to boost your user experience on the Website.
  • Analytics cookies. These cookies are used to track how users navigate and interact with the Website, for instance, the number of users on the Website, how long they stay on the Website for, and what parts of the Website they visit. The information collected is used to help us improve our Website.

To give you control, we provide you with a Cookie Consent Tool, which allows you to review the first party and third-party cookies placed through our Website and adjust your cookie settings, including whether to accept or decline such cookies. You can access the Cookie Consent Tool by clicking the “Cookie Consent” link at the bottom of every page of the Website or by setting up your preferences in our cookie banner. In addition, you can manage cookies through the settings of your internet browser. If you delete your cookies, your access to some functionality of our Services and features of the Website might be degraded or restricted.

5. Direct marketing

We may contact you via email from time to time to provide you with information relating to products or services that may be of interest to you. We are committed to keeping your email address confidential and will not disclose your email address to any third parties except as stated in this Privacy Policy for the purposes of utilizing a third party service provider to send such emails. We will maintain the information sent via email in accordance with applicable laws and regulations. In compliance with the CAN-SPAM Act, all emails sent from us will clearly state who the email is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. Please note that, in the event that you unsubscribe from receiving communications relating to marketing or advertising, we may nevertheless continue to contact you for the purposes of carrying out your instructions, enabling you to make any purchases you request, or as required or permitted by applicable law.

6. Third party service providers

We use third party payment processors to assist us in processing your payment information securely. We will not store or collect your payment details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their own Privacy Policies. We suggest that you review their respective privacy policies.

7. Disclosure of Personal Data

In order to provide some of our Services, we may need to share your Personal Data with certain third parties that work with us, any other affiliates and subsidiaries we rely upon to assist in the operation of the Website and Services available to you, in the following circumstances:

  • We may share your Personal Data with recipients within RGMS LLC, for the purposes of provision Services and operating the Website, or otherwise for the purposes set out in this Privacy Policy
  • We may share your Personal Data with recipients outside RGMS LLC, for the purposes of provision Services and operating the Website, or otherwise for the purposes set out in this Privacy Policy.
  • We may use third party service providers to help us operate our business and the Website, provide you with products or services you have selected, or to administer activities on our behalf, such as sending out newsletters or surveys. We may share your Personal Data with such third parties for the purposes set out in this Privacy Policy.
  • Subject to obtaining your consent, we may share your Personal Data with our third party marketing partners, for direct marketing purposes. You may withdraw your consent at any time, or object at any time to the Processing of your Personal Data for direct marketing purposes.
  • If we sell, merge or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, liquidation or other restructuring), we may disclose your Personal Data to the prospective seller or buyer, or their representatives, provided that we have first taken reasonable steps to ensure the security and confidentiality of your Personal Data.

We also may disclose your Personal Data:

  • to the extent necessary to establish, exercise or defend legal claims;
  • to the extent required by applicable laws;
  • in response to legal requests from government agencies and law enforcement authorities;
  • when disclosure is necessary to prevent physical harm or material loss; or
  • for the purposes of investigating and/or preventing unlawful activity.

These third party service providers are not authorized to use or disclose your Personal Data except as necessary to perform Services on our behalf, or in order to perform their designated functions or comply with legal requirements.

8. International Transfer of Personal Data

We may make use of processing facilities controlled or operated by our third party service providers, located in jurisdictions other than the jurisdiction in which your Personal Data were originally collected. In particular, the content and features of the Website may be provided by means of servers located outside your jurisdiction (including, but not limited to, servers located in the United States). Your Personal Data may be transferred to, and processed using, those servers or other processing facilities, as part of the operation of the Website or in connection with any of the processing purposes set out in this Privacy Policy, subject to compliance with the provisions of applicable laws (e.g., by implementing EU Standard Contractual Clauses). These transfers are necessary in order to provide our products and services to you in an efficient and effective manner. By providing Personal Data to the Company under this Privacy Policy, you acknowledge that your Personal Data may be transferred to locations outside your jurisdiction. If you do not wish for your Personal Data to be transferred to other jurisdictions, please do not provide your Personal Data to, nor use any part of the Service and/or Website.

9. Your rights regarding your Personal Data

Depending on your location and subject to applicable law, you may have the following rights described here with regard to the Personal Data we control about you:

(i) the right to request confirmation of whether we process Personal Data relating to you, and if so, to request a copy of that Personal Data;
(ii) the right to request us to rectify or update your Personal Data that is inaccurate, incomplete or outdated;
(iii) the right to verify the accuracy of your information and ask for it to be updated or corrected;
(iv) the right to withdraw consent where you have previously given your consent to the processing of your personal information;
(v) the right to object to the processing of your personal information if the processing is based on our legitimate interests other than consent. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.
(vi) the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it;
(vii) the right, under certain circumstances and applicable law, to obtain the erasure of your Personal Data from us;
(viii) the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another company without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

Any requests to exercise your rights can be directed to the Company through the Contact details provided in this Privacy Policy. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Data unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.

10. GDPR Statement for the European Economic Area residents (“EEA residents”)

General Data Protection Regulation Privacy Statement (“GDPR Statement”) This GDPR Statement applies to persons residing within the European Economic Area (“EEA”), including those based in the United Kingdom. This GDPR Statement supplements the Privacy Policy, however, this GDPR Statement shall prevail when conflicting with the Privacy Policy as to persons residing in the EEA.

Controller of Personal Data

RGMS LLC is the data controller of personal information we collect, however, in accordance with applicable data privacy law, we have appointed a representative within the European Union. The contact details of our European Union representative is:
Email: remi@sharpsheets.io
Attention: Privacy Officer

The EU representative role in this respect is limited solely to being a contact point for questions on data protection from the EU residents and data protection supervisory authorities. For the avoidance of doubt, the EU representative cannot field other communications or legal processes on behalf of RGMS LLC.

Your rights under GDPR

Your rights with respect to your own personal data include the following:

  1. The right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
  2. The right to request rectification of your personal data if it is inaccurate. You may also supplement any incomplete personal data we have.
  3. The right to request erasure (deletion) of your personal data if:
    • your personal data is no longer necessary for the purposes for which we collected or processed them; or
    • you withdraw your consent if the processing of your personal data is based on consent and no other legal ground for processing exists; or
    • you object to the processing of your personal data and we do not have an overriding legitimate ground for processing; or
    • your personal data is unlawfully processed; or
    • your personal data has to be erased for compliance with a legal obligation.
  4. The right to restrict the processing of personal data, if:
    • the accuracy of your personal data is contested by you, for the period in which we have to verify the accuracy of the personal data; or
    • the processing is unlawful and you oppose the erasure (deletion) of your personal data and request restriction; or
    • we no longer need your personal data for the purposes of processing, but your personal data is required by you for legal claims; or
    • you have objected to the processing, for the period in which we have to verify overriding legitimate grounds.
  5. The right to data portability. You may request that we send this personal data to another third-party controller, where possible. You are able to perform this right only if it relates to personal data you have provided to us where the processing is based on consent or necessity for the performance of a contract between you and us, and the processing is conducted by automated means.
  6. The right to object to the processing of your personal data. We will comply with your request, unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.
  7. You also have the right to lodge a complaint before your national data protection authority.

We may request specific information from you to confirm your identity and ensure your right to access your personal data or exercise any of your rights. This is a security measure to ensure that personal data is not disclosed to any unauthorized person. To exercise your rights you can file a request directly to our EU representative.

Legal basis of Personal Data use

Pursuant to GDPR, we will use your personal data in one or more of the following circumstances: Where we need to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our business legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation. With your consent.

International Transfers

By using our Services, you understand that your Personal Data may be stored or transferred to countries outside the EEA for the purposes described in this GDPR Statement. When we store or transfer your Personal Data outside the EEA, we take the following measures to ensure that your personal data is securely protected. Whenever we transfer your personal data outside the EEA, we do it in accordance with applicable law and we will ensure a necessary degree of protection by implementing appropriate safeguards. Transfers of personal data are made either to: countries recognised by the European Commission as providing an adequate level of protection; or countries which do not offer adequate protection, but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.

11. Information security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, organizational and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Data in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Data, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

12. Retention of information

We will retain and use your Personal Data for the period necessary to comply with our legal obligations, resolve disputes, and perform our contracts unless a longer retention period is required or permitted by applicable law. We may use any aggregated data derived from or incorporating your Personal Data after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

13. Do Not Track signals

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website and Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Data.

14. Data breach

In the event we become aware that the security of the Website and Services has been compromised or users Personal Data has been disclosed to unauthorized third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by applicable law. When we do, we will send you an email.

15. Privacy of children

We do not knowingly collect any Personal Data from children under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Website and Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Privacy Policy by instructing their children never to provide Personal Data through the Website and Services without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Data to us through the Website and Services, please contact us. You must also be at least 16 years of age to consent to the processing of your Personal Data in your country (in some countries we may allow your parent or guardian to do so on your behalf).

16. Changes and amendments to our Privacy Policy

We reserve the right to modify this Privacy Policy or its terms relating to the Website and Services from time to time at our discretion and will notify you of any material changes to the way in which we treat Personal Data. When we do, we will revise the updated date at the bottom of this page. We may also provide a notice to you in other ways at our discretion, such as through contact information you have provided. Any updated version of this Policy will be effective immediately upon the posting of the revised version unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy will constitute your consent to those changes. However, we will not, without your consent, use your Personal Data in a manner materially different from what was stated at the time your Personal Data was collected.

17. Contacting us

If you would like to contact us to understand more about this Privacy Policy or wish to contact us concerning any matter relating to individual rights and your Personal Data, you may do so via info@sharpsheets.io.

This document was last updated on June 16th, 2022