General Privacy

Effective Date: 1/3/2018

This privacy policy was last modified on January 3, 2018. As we update and expand our website, this Privacy Policy may change, so please check this web page for updates to our Privacy Policy. This privacy statement describes how, Inc. ("Shibumi") collects and uses the personally identifiable information ("Personal Information") you provide on our Web site,, and our service. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. We will not use or share your Personal Information with anyone except as described in this Privacy Policy.

Shibumi complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU) and Switzerland to the United States, respectively. Shibumi has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit

For non-U.S. users, we may transfer Personal Information and usage statistics that we collect about you from your country or jurisdiction to other locations where our data and service are stored and provided, including the United States. Privacy and data protection laws in your jurisdiction may differ from U.S. law. By using the service, you consent to the transfer of information to the U.S. and the use and disclosure of information about you, including Personal Information, as described herein.

Collection of Information

When you visit our Website we may collect information regarding your visit from your computer. Such information helps us to determine information about how you found our Website, the date that you visited our Website and search engines that may have led you to our Website. We collect this information in order to continually improve and enhance the functionality of and our service.

Generally, you may provide us with two types of information, User Content, which may include Personal Information, and Website Usage Information, both of which are discussed in greater detail below.

We collect and store the following personal information from you

  • Contact Information such as name, email address, mailing address, phone number
  • Unique Identifiers such as user name and password
  • Information about your business such as company name, company size, business type and role
  • IP address, browser type, operating system, mobile carrier, and your ISP, and receive the URLs of sites from which you arrive or leave the Shibumi website, or sites that have embedded Shibumi platform technology

We use this information to

  • Send you requested product or service information
  • Send product updates
  • Respond to customer service requests
  • Administer your account
  • Send you a newsletters and/or marketing materials
  • Display content based upon your interests

Decision to Opt-Out

You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or you can contact us at Although you may opt-out of receiving promotional information from Shibumi, we may still contact you in connection with any transactions, activities, solicitations, relationships and requests made through our service or through

Information Sharing

We will share your personal information with data processors that provide services or integrations with the Shibumi application only in the ways that are described in this privacy statement. We do not sell your personal information to third parties. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield, Shibumi is potentially liable.

We may provide your personal information to companies that provide services to help us with our business activities such as offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us. Upon your consent and if enabled in your enterprise, we will share your personal information with third parties that provide integrations with the Shibumi application.

We may also disclose your personal information

  • to comply with a lawful request by public authorities, including to meet national security or law enforcement requirements
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request,
  • if Shibumi is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information,
  • ownership or uses of your personal information, as well as any choices you may have regarding your personal information,
  • to any other third party with your prior consent to do so.

Cookies and Other Tracking Technologies

As is true of most Web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole for the purpose of improving our products and services.

We do link this automatically-collected data to personally identifiable information. IP addresses are tied to personally identifiable information to ensure security-access control and enable comprehensive security-audit functionality.

We use a third-party tracking service Google Analytics that uses scripts to track non-personally identifiable information about visitors to our site in the aggregate. We capture timing information related to performance of the service, page loads to identify trends and popularity of certain features and functions of the service, as well as geographic information to enable us to provide high-performance load balancing and low latency user access.

A cookie is a small text file that is stored on a user's computer for record-keeping purposes. We use cookies on this site. Currently, we use session ID cookies to make it easier for you to navigate our site, including storing your authentication ID, so you don't have to login more than once and tracking and targeting the interests of our users to enhance the experience on our site. The Shibumi session ID cookie expires after 3 hours of inactivity. You can remove these cookies by following directions provided in your Internet browser's "help" file.


We partner with a third party ad network to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.


The security of your personal information is important to us. When you enter sensitive information (such as login credentials), we encrypt the transmission of that information using 256-bit transport layer security technology (TLS).

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. There is no guarantee that information may not be accessed, copied, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications at all times.

If you have any questions about security on our Web site, you can contact us at

Information Related to Data Collected for our Clients

Shibumi collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes.

We collect information for our clients, if you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the client that you interact with directly. Shibumi may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.

Shibumi acknowledges the right of individuals to access their personal data, but in our capacity as a data processor, Shibumi has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Shibumi's Client (the data controller). If the Client requests Shibumi to remove the data, we will respond to their request within 30 days.

Shibumi will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Shibumi will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Social Media Features:

Our Web site includes Social Media Features, such as the LinkedIn "following" and Facebook links. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Access to Personally Identifiable Information

If your Personal Information changes, or if you no longer desire our service, you may correct, delete/remove, or deactivate by making the change on our member information page or by emailing our Customer Support at or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request within 30 days.

Data Retention

We will retain your information for as long as your account is active or as needed to provide you or your sponsoring organization services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, improve our service offering, and enforce our agreements.

Notification of Privacy Statement Changes

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, Shibumi commits to resolve complaints about your privacy and our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Shibumi at:
50 Washington Street
Suite 302E
South Norwalk, CT 06854

Shibumi has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint.

If your complaint is not satisfactorily addressed, and your inquiry or complaint involves human resource data, you may have your complaint considered by an independent recourse mechanism: for EU/EEA Data Subjects, a panel established by the EU data protection authorities (“DPA Panel”), and for Swiss Data Subjects, the Swiss Federal Data Protection and Information Commissioner (“FDPIC”). To do so, you should contact the state or national data protection or labor authority in the jurisdiction where you work. Shibumi agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel and the FDPIC.

Should your complaint remain fully or partially unresolved after a review by Shibumi, BBB EU PRIVACY SHIELD and the relevant DPA, you may be able to, under certain conditions, seek arbitration before the Privacy Shield Panel. For more information, please visit

Shibumi is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).