Shintech Inc. Privacy Policy   

We at Shintech, Inc. (“Shintech”, “we”, “our”, or “us”) respect your privacy. This Privacy Policy (“Policy”) explains how we collect, use, and disclose information from and about you (“your information”) that we receive in the ways specified below.

This Privacy Policy outlines Shintech Inc. practices with respect to information collected from users who access our website at www.shintech.com, or otherwise share personal information with us users. 

Processing of your personal information (meaning, any information which may potentially allow your identification) is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. 

We collect two types of data and information from Users. 

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (Non-personal Information). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of information Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

• Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
  
• Registration information: When you register to our Site you will be asked to provide us certain details such as: full name; e-mail or physical address, and other information.  

How we collect your information and what information we collect depends on how you interact with the Site.  Shintech is the congroller of data collected from visitors to the Shintech Site and from Customers when they interact with Shintech.

We collect information that you provide to us, information that we collect automatically, and information from other sources. 
Information You Provide to Us.

We collect information you provide to us, depending on how you use the Site, when, for example, you send an inquiry via our Contact Us page and use the form. Depending on whether you are a Site visitor or Customer, this information may include:

• Contact Information such as your name, company name and details, mailing address, email address, and phone number;
• Messages you send to us;
• Any other information provided to us such as feedback.

You can choose not to provide us with certain information, but then you may not be able to take advantage of all of the functionality of our Site.

Information We Collect Automatically.

When you interact with the Site, we may automatically collect information about your browser, device, and use of the Site, including, but not limited to IP address, approximate location, information about your activity on the Site (such as page views and features you use), device type, browser type, operating system and version, the web page you were visiting before you came to the Site, information you search for on the Site, locale preferences, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning your files, website alias, responsive website or mobile website URL, and website URL. Somes data is collected using cookies and similar technologies. To learn more about cookies, please read our Cookies Policy. 

Information From Other Sources.
We may collect information about you from publicly and commercially available sources, as permitted by law, including but not limited to publicly available directories, social media, advertisers and business partners, and Customers.

We may use Site Data for the following purposes, unless indicated otherwise:

• To provide and improve the Site;
• To provide customer support and respond to your queries;
• To communicate with you and to provide you updates, and other information related to the Site (subject to any preferences we offer and/or required by law);
• To advertise and market to you, in accordance with applicable legal requirements and subject to any preferences we offer and/or required by law);
• To analyze and research the functioning and use of the Site and develop new features and to conduct surveys;
• To prevent fraud and protect the security and integrity of the Site; and to protect the rights, safety, security, interests, and property of Shintech, Customers, End Customers, End Users, our partners, third parties, and members of the public;
• To enforce our policies;
• To comply with legal requirements, including applicable laws, regulations, and legal process (e.g., subpoenas, warrants, or preservation requests); and
• For any other purpose, with your consent.

We may aggregate, de-identify and/or anonymize any information collected through the Site so that such information is no longer reasonably capable of being associated with you. We may use aggregated or anonymized information (or information that was never associated with you) for any purpose, including for research and marketing purposes, and we may also share such information for any purpose with any third parties, at our discretion.

The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to process your information. Our legal bases for processing your information as described in this Policy are as follows:

• Performance of contract: Where use of your information is necessary to perform our obligations under a contract or commitment to you.
• Legitimate interests: Where use of your information furthers our legitimate interests or the legitimate interests of others. For example, to provide security for our Site, operate our business, make and receive payments, assert and defend our legal rights and those of others, market and improve and optimize our Site, and prevent fraud.
• Compliance with legal obligations: Where we use your information to comply with applicable legal obligations. For example, complying with valid law enforcement and court orders.
• Consent: Where you have consented to our processing of your information for a particular purpose.

For the purposes discussed in this Policy, we may combine the information that we collect through the Site with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy.

We may share your information under the following circumstances:

• Internally - We may share your information with companies in our group and our employees as necessary to provide you with our Services and operate our business efficiently and effectively.
• Service Providers - We may share your information with third parties that work on our behalf to help us operate our business and provide the Services by performing services that include, without limitation: maintenance, website hosting and database management services, data security, storage, analytics, website administration, legal or tax services, email management, consent management, and advertising. Service Providers must comply with this Policy and may only use your information to provide us with their services.
• Affiliates and Partners - We provide your information to our affiliates or partners, if (i) you have a relationship with that affiliate or partner either online or offline (non-Internet), including in particular where you contract with such affiliate or partner independently of Shintech, (ii) you have visited the affiliate or partner's website that links to or mentions our website, or (iii) you have registered for our Site through the partner’s or affiliate’s program or website.
• Marketing partners – in some cases, we share your information for communicating targeted advertising and promotional materials. 
• As required or permitted by law - We cooperate in good faith with government and law enforcement officials and private parties to enforce and comply with the law and protect the rights of Shintech, its customers and third parties. We will disclose your information if we, in our sole discretion, believe it necessary or appropriate: to respond to claims and legal process (including but not limited to subpoenas); to protect our or a third party's property, safety, or rights; to address any activity we consider to be, or to pose a risk of being, illegal, unethical or legally actionable; or as otherwise required or permitted by law. 
• Business Transactions - We may share your information if we sell, transfer or otherwise share some or all of our assets in connection with a merger, acquisition, reorganization or sale of all or substantially all of our shares or assets or a similar transaction, in the event of bankruptcy, or contemplated of or diligence leading up to a potential corporate transaction.
• With Your Consent – We share your information when we have your consent to do so.

You may request to: 

1. Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information. 
   
2. Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format. 
   
3. Request rectification of your personal information that is in our control.
   
4. Request erasure of your personal information. 
   
5. Object to the processing of personal information by us. 
   
6. Request to restrict processing of your personal information by us.
   
7. Lodge a complaint with a supervisory authority.
   

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. 

Marketing Emails. You may choose not to receive our promotional or marketing emails by clicking on the “unsubscribe” link in those emails. Please note that even if you unsubscribe from our marketing emails, we will continue to send you transaction-related emails regarding products or Services that you have requested, certain non-promotional emails about us and our Services, and responses to your queries or feedback. 

Your Rights.
Depending on your jurisdiction of residence, you may have the right to request:

• Access to, a copy of, and certain information about our processing of, your information;
• Correction of inaccuracies in your information;
• Deletion of your information, subject to any legal or other rights we have to retain certain information; and
• Restriction of the processing of your information; you also have the right to object to our processing of your information in some circumstances.

These rights are subject to applicable exceptions, and we will need to verify your identity before processing your request. If you would like to submit a request relating to your information, please contact us using one of the methods in the section below titled “Contacting Us.” 

If you contact us to exercise a right with respect to End Customer or End User Data, for which we are a processor/service provider, we will forward this request to the appropriate Customer who is responsible for responding to your request if we can identify the Customer, otherwise contact your controller directly to exercise these rights. 

If you are a resident of the European Economic Area (“EEA”), the United Kingdom, or the state of California, please see the section below titled “Notice to EEA and UK Residents” or “Notice to California Residents” (as applicable to you) for more information about your rights. 

If you wish to exercise any of the aforementioned rights, or receive more information, please contact us.

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations. In general, personal data relating or our customers will be retained for the duration of the engagement with the customer, and perhaps for a period of up to seven (7) years followign the termination of services to that customer.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

When you interact with the Site, we (and third parties acting on our behalf) automatically collect certain information about your browser, device, and use of the Services through cookies, pixel tags, web beacons, local storage, and other similar technologies. 

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We can only control the cookies on our Site. To manage your preferences with regard to cookies on our Site, please visit our page on Cookies. It outlines Cookie Control and Consent and states

“When you first visit our website, you will see a cookie consent banner. You can choose to accept or manage your cookie preferences.”

You can also manage or delete cookies at any time by adjusting your browser settings. Please note that disabling cookies may impact the functionality of the website.

 Settings. Customers may place cookies on Customer Sites. Shintech does not control those cookies, and the cookie preferences for our Site do not apply to the cookies on Customer Sites, or third party service providers (affiliates and partners) with whom you contract. Your web browser may allow you to manage cookies and local storage. Each browser is different, so please, follow the directions provided in your browser’s “help” section to manage cookies. Please note that if you delete or disable cookies from our Services, some parts or functions of the Services may not work properly for you.

“Do Not Track” Signals. “Do-not-track” (“DNT”) is a setting offered by some browsers. DNT signals are not yet uniform, so we, like many other website operators, do not currently recognize or respond to DNT signals.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

The Site may contain third-party content or links to third-party websites and services. When you interact with such content or visit a third-party website, or install a third party app or use a third party service, you will be providing third parties with your information. Such third-party content and sites are not governed by this Policy, and we have no control over how third parties use your information, nor are we liable for such third parties’ use or disclosure of your information. A third party’s use of your information is subject to that third party’s privacy policy and your contract with them. Before you share your information with a third party, we encourage you to read the third party’s privacy policy and any other relevant terms.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy. 

This Privacy Policy outlines Shintech Inc. practices with respect to information collected from users who access our website at www.shintech.com, or otherwise share personal information with us users. 

We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your information. However, because no security measures are perfect, there is always some risk involved in transmitting your information over the internet. We cannot guarantee the security your information, and you transmit it to and through the Services at your own risk. 

You can help prevent unauthorized access to your account and information. You are solely responsible for all activity that takes place through your account, including any unauthorized use. 

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Notice to Non-U.S. Users and Consent to Transfers

Shintech and our computer systems are based in the United States, so we will process your information in the United States, where the privacy laws may not be as protective as those in your jurisdiction. By using the Site, you understand and agree to the transfer of your information to the United States and to the processing of that information as described in this Policy. 

Where required, we will use appropriate safeguards for transferring the data of residents of the EEA or UK. This may include signing Standard Contractual Clauses (“SCCs”) in the form issued as part of the EU Commission Decision (EU) 2021/914 that govern the transfers of such data. We receive personal data in the USA, including in reliance on the Data Privacy Framework as detailed below. We may conduct onward transfers based on DPF or another mechanism, generally the SCCs.

For non-EEA/UK residents, we will transfer your data in accordance with applicable law.

Notice to EEA and UK Residents

Right to Complain. We encourage you to contact us directly and allow us to work with you to address any concerns you might have about our privacy practices. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside or work, or the place of the alleged infringement. You have the right to do so if you consider that the processing of Personal Data relating to you infringes applicable data protection laws.

Data Protection Framework

Through our content management system Duda, Shintech complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Duda has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Duda has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. With respect to personal data received or transferred pursuant to the Data Privacy Frameworks, Duda is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Data Privacy Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to privacy@duda.co. If requested to remove data, we will respond within a reasonable timeframe.

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

Categories of Personal Information We Collect.
We collect information from and about you as specified in the section above titled “Types of Information We Collect.” This information includes the following categories of personal information: 

• Identifiers (such as name, address, IP address, and email address);
• Commercial information (such as products or services purchased, obtained, or considered);
• Payment information;
• Internet or other electronic Network Activity Information (such as browsing history, search history, and information regarding your interaction with our Services);
• Location Data; 
• Audio information (specifically, information from customer service calls, as explained above); and
• Inferences drawn from any of the above information.

How We Use and Share These Categories of Personal Information.
We use the above categories of personal information for the purposes listed in the section above titled “How We Use Your Information,” and we disclose your information to third parties as described in the section above titled “How We Share Your Information,” subject to the requirements of the CCPA.

The CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. To the extent that re-targeted advertising is a sale of personal information, in that regard we may be selling personal information; to opt out of such re-targeted advertising, please use the cookie tool to block cookies on your browser and device.

Your Rights.
California residents (or their authorized representative) have the right to request the actions listed in the section above titled “Your Rights.” To request to exercise any of these rights, please contact us using one of the contact methods in the section below titled “Contacting Us.”: 

The CCPA further provides you with the right to information about the financial incentives that we offer to you, if any, and to not to be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, we need certain information to provide the Services to you. We also will take reasonable steps to verify your identity before responding to a request. 

Shine the Light Disclosure.
The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you. 

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists. 

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us.

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us by following this link.

Shintech Inc.

Last Modified 06/30/2026