Privacy Policy

Effective Date: 01/03/2019

This Privacy Policy covers Sharetini, Inc., a Delaware Corporation’s (“we” or “Sharetini”) (“Sharetini”) policies on the collection, use, and disclosure of Personal Data/Personally Identifiable Information (as defined by applicable law and hereinafter collectively referred to as “Personal Data”) when visitors, authorized service partners and account holders (collectively “Users”) access www.sharetini.com (“Site”) and/or the Sharetini mobile applications (the “Mobile App”) (collectively the “Platform”) and the software and services made available through the Platform (collectively the “Services”).

Sharetini, Inc. is Delaware corporation with offices in the United States. Sharetini collects Personal Data from its users around the world and processes, transfers and stores data within the United States.  By checking the “I consent to the Privacy Policy” box and subject to your opt-in/opt-out preferences, you consent to the collection, use and disclosure practices identified in this Privacy Policy. 

  1. What Information Is Collected by Sharetini And How Is It Used?

Account Creation Information:  When creating an account, you must register either by providing an email and a password, or by registering through your existing Facebook account.  Sharetini will verify the account by sending an email to the designated email address or text to the designated mobile phone before finalizing registration.   The collection of this information is necessary to fulfill our contractual obligations and to provide the Services to you.  In-App settings allow you to request that Sharetini delete any data our app may have pre-populated from your Facebook account at any time.  Your email may also be utilized to (i) provide information regarding our Services; and/or (ii) to communicate material changes to our Terms of Service and Privacy Policy.  

Account Profile:  You may create an account profile and optionally provide additional information within your profile to assist you in connecting with others looking to co-own property, including uploading a photo and setting location and profile-access preferences. Profile information is accessible to other Sharetini account holders.  

Email Addresses & Contact Information:  Users may optionally provide their email address and/or other contact information to Sharetini to contact us through the Platform with questions about our Platform and Services.  Users may also optionally subscribe to our newsletters and may unsubscribe at any time through the opt-out link contained within those communications. 

Cookies:  Sharetini utilizes cookie technology to gather information on Internet use in order to serve its Users more effectively. As described in Section 2, Sharetini also utilizes third party analytics services which may also use tracking cookies to provide information about the use of our Platform. Users can set your browser to remove or reject cookies and/or accept or refuse cookies on the cookie consent banner on the site itself; however some Platform features or Services may not work properly without cookies. 

  1. Is Information Collected By Or Disclosed To Third Parties? 

Sharetini does not sell, rent, or lease Personal Data to any third parties.  However, Personal Data is shared with third parties as follows: 

Account Registration:  Subscribers may optionally register their account through Facebook. If you register an account using your Facebook login credentials, it will enable Facebook to collect an account holder’s Personal Data in accordance with the policies and practices disclosed in Facebook's Data Policy.  You should click on the hyperlink to review the applicable privacy policies for more detail about information collected from Facebook. You have the ability to modify your privacy settings through your Facebook account.

Sharetini Partners:  Sharetini’s Mobile App marketplace helps authorized services partners connect with account holders looking to co-own property and offer their resources, advice and services for co-ownership based transactions. Your profile is accessible for viewing by Partner account holders and users can connect through to share information or engage in in-app communications. 

Integrated API’s - Geolocation Data: Sharetini has integrated the Google API to incorporate Google Maps and to utilize geolocation in connection with the Services. Information is collected in accordance with Google's Privacy Policy.  You can review and manage key privacy settings using Google’s Privacy Checkup tool.

Anonymous Data - Analytics: Sharetini uses third party analytics services to learn how Users use the Platform and Services so that we can review and improve our Services:

  • Google Analytics: Google Analytics is a web analytics tool collects information anonymously. It provides a report to Sharetini with website trends without identifying individual visitors.  Google Analytics collects anonymized information in accordance with their Privacy Policy. You may opt-out by installing Google Analytics Opt-out Browser Add-on. 

Hosting Services:   Personal Data collected is shared with Amazon Web Services, to facilitate its cloud hosting services. Please click on the hyperlink for more information about AWS’ data collection and privacy policies. 

Third Party Advertising/Re-Targeting Services: When accessing the Platform, third party advertising services may place a cookie on your browser, which may be used to target relevant advertisements to you when you visit third party websites.  Users may opt-out from receiving targeted advertisements by visiting the (1) Network Advertising Consumer Opt-Out page, (2) Digital Advertising Alliance Opt-Out page, and/or (3) the opt-out provisions pertaining to the applicable advertising services/retargeting provider. 

Social Plug-Ins:  Users may follow Sharetini and/or share information on Facebook, Twitter, Pinterest, Google and LinkedIn. Users should click on the hyperlinks for each site to review the applicable privacy policies for more detail about information collected from these sites. 

Other Potential Third Party Disclosures: Personal Data may also be disclosed to third parties to serve our legitimate business interests as follows: (1) as required by law, such as to comply with a subpoena, or similar legal process, (2) if Sharetini is involved in a merger, acquisition, or sale of all or a portion of its assets, (3) to investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (4) enforce our agreements with you, and/or (5) investigate and defend ourselves against any third-party claims or allegations. We will use commercially reasonable efforts to notify users about law enforcement or court ordered requests for data unless otherwise prohibited by law.

  1. How Does Sharetini Comply With The Children’s Online Privacy Protection Act and GDPR Regulations Relating to Children?

Only persons age 18 or older are authorized to create an Sharetini account.  We do not knowingly collect Personal Data from anyone under the age of 18.  If a parent or guardian becomes aware that his or her child (a) under the age of 16 in applicable EU Member Countries, or (b) under the age of 13 in the U.S. and applicable EU Member Countries,  has provided us with Personal Data without their consent, he or she should contact Sharetini at privacy@sharetini.com. We will delete such Personal Data from our files within a commercially reasonable time, but no later than required under the applicable law relating the child’s country of residence. 

  1. How Long Does Sharetini Retain Personal Data Collected? 

We will retain account and purchase data as long as it is necessary to provide our Services to our Subscribers.  When a Subscriber’s account is terminated or expires,  Personal Data collected through the Platform will be deleted in accordance with the requirements of applicable law.  Personal Data obtained from Site visitors will be maintained as long as it is necessary to provide requested communications and information-based services or until a Visitor exercises its right to opt-out of requested communications or information-based services.  Anonymized and Pseudo-anonymized data will be retained as long as Sharetini determines such data is commercially necessary for it legitimate business interests. 

  1. EU General Data Protection Regulation (“GDPR”) Notices

Data Controller.  The Personal Data input by users is controlled by Sharetini, Inc.,

1225 4th Street, Unit 103, San Francisco, CA, 94158.  You may contact us at any time by emailing us at privacy@sharetini.com. 

We will only collect and process Personal Data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you), and “legitimate interests.” Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.  If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us at privacy@sharetini.com.

Users within the EU may email Sharetini  at privacy@sharetini.com in order to exercise their GDPR rights to: 

  • Access, review, restrict processing of, or otherwise request erasure of your Personal Data;
  • Obtain the identity of the source of any Personal Data collected;
  • Request correction of any errors contained within your Personal Data;
  • Request transfer your Personal Data to another service provider;
  • Object to the manner in which your Personal Data is processed; or
  • Lodge a complaint with a supervisory authority.

Where we rely on your consent to collect Personal Data, you may withdraw your consent either through the opt-out links provided in this Privacy Policy or through the contact information contained within this Section.

For all GDPR-based requests made pursuant to this section, Sharetini will (a) respond as required under applicable law, (b) provide a copy of any requested Personal Data in a structured, commonly used and machine-readable format, and (c) transmit such Personal Data to another service provider without restriction in accordance with applicable law.

  1. Transfer of Personal Data to Servers Hosted within the United States. 

PERSONAL DATA COLLECTED BY THE PLATFORM IS HOSTED ON SERVERS LOCATED WITHIN THE UNITED STATES.  If you are attempting to access the Platform from a physical location within the European Union, Asia, or any other region with laws or regulations governing personal data collection, your continued use of the Platform constitutes your express consent to the transfer of such Personal Data to the United States. 

  1. What Is Sharetini Security Policy? 

We have implemented reasonable administrative, technical and physical security measures to protect your personal information against unauthorized access, destruction or alteration. However, although we endeavor to provide reasonable security for information we process and maintain, no security system can ever be 100% secure.  

For information relating to Personal Data stored by Amazon Web Services, please see the AWS Cloud Security Policy for more information on its security practices.

  1. How Does The Platform Respond To “Do Not Track” Signals?

“Do Not Track” is a feature enabled on some browsers that sends a signal to request that a website disable its tracking or cross-Platform user tracking. At present, the Platform does not respond to or alter its practices when a Do Not Track signal is received. 

  1. How Will I Be Notified Of Changes To Your Privacy Policy? 

If we make material changes to our Privacy Policy, we will notify you by (1) changing the Effective Date at the top of the Privacy Policy, (ii) sending an email to all active account holders, and (iii)  add a banner/notification to the Platform itself.  Express consent will be obtained when required for any material changes in Sharetini’s collection and use practices. 

  1. Contact Us

If you have any questions regarding your Personal Data or about our privacy practices, please contact us at: Sharetini, Attention: Sharetini, Inc.,, 1225 4th Street, Unit 103, San Francisco, CA, 94158.  or at privacy@sharetini.com