PRIVACY POLICY

This privacy policy (“Privacy Policy”) governs the collection and use of information gathered from users through shomagroup.com (“Website”). The Website is operated by Shoma Alliance Management Corp. (“Shoma Group”). By using our Website, including using the site for a professional organization you represent (“Organization”), you are agreeing, both for yourself and the Organization you represent, to the terms stated in this Privacy Policy (and to our Website’s ), which are incorporated by reference. The term “you” used here refers to you, the Organization you represent or any users you may authorize on or through the Website. The terms “we” or “us” refers to the employees, agents or assigns of Shoma Group. Please review both of this document and our document before you use the Website, to be sure you agree with everything stated and our information collection and use practices.

1. Type of Information Collected, and When It May Be Collected.

a. Your Information. As you use the website, we may gather information from you, including information by which you may be identified (“Personally Identifiable Information”). We also may collect information from you if you provide it voluntarily, through the Website, such as if you sign up to use website services, including using an Organization-assigned user ID, or if you Email us with information. Personally Identifiable Information we gather in these ways may include your name, Federal Employer Identification Number (FEIN) or Social Security Number (SSN), Email address, address, telephone number, place of work, etc. We may also gather information from you and your use of the website through use of Cookies, such as the nature of your use of the Website, your Email address, your password and information about your computer. Cookies include information computers or servers store on your computer or server, about you, your computer or your organization when you visit a website. Cookies enable the computer, server or network to recognize the person or their computer when they return to the Website. You may be able to set your browser to disable some or all Cookies, or to notify you when an attempt to set a Cookie on your computer has been initiated.
 
b. Personal Information. A key function of this website is to provide a system for technical communication through which Providers or users acting on their behalf may send and receive information and/or queries about their clients, potential clients, property owners, agents, brokers, or other, similar recipients and sources. The information exchanged includes personal information which can be used to identify individuals and/or clients. In providing this system, for purposes of this Privacy Policy, Shoma Group does not consider its action of handling, transmitting, and / or conveying of requests, information or responses as use or, or disclosure of, that information. In that capacity, Shoma Group is merely providing a service to its users, and is acting as an information carrier. However, all such communication and Personal Information exchanged through this website may be stored by us (or by our service providers for us, only as required by Law. By using this website to send or receive any Personal Information, you are acknowledging and confirming that you have previous received any and all necessary permission and authority to do so.

2. How We Use and Disclose the Information.

a. We (And Our Agents or Assigns) may use and disclose information we gather about you, including your Personally Identifiable Information: To operate the Website; To perform the functions and provide the services and/or goods you request; To improve, correct and maintain the Website; To facilitate and improve your experience on the Website; To contact you about the Website and new features and services available; and, To provide the necessary information to our Service Providers as needed, so they can perform the services called for or to help them interact with the Website and/or our program operations, its services or products and / or its information-reporting systems, and as otherwise stated in this Privacy Policy.
b. With Respect to Communications, including Personal Information exchanged through the Website and/or its services, the communications and the information conveyed may be stored by us or by our Service Providers, on our behalf, as required by Law.
c. With Respect to Any Information gathered through the Website, including Personally Identifiable Information and Personal Information, unless prohibited by law, we may: (a) Aggregate the information for reporting or other purposes and, in so doing, use the aggregated information so that individuals may not reasonably be identified and, once the aggregated information has been de-identified, we may use it and/or disclose the information to other organizations for any purpose; (b) Share it with and transfer our rights in it to any successor entity to Shoma Group, which entity would have the right to use and disclose the information as Shoma Group did; and, (c) Share it with our agents and/or business partners for deployment and marketing to you of Shoma Group services and/or products. In addition, unless prohibited by law, we may use and disclose this information, including Personally Identifiable Informationand Personal Information: If (w) we believe that any law or regulation requires us to do so; (x) To respond to a subpoena or governmental request; (y) As we deem advisable to protect our safety, rights, privacy or property, or that of others; and (z) To enforce or respond to a possible violation of any law or regulation.
 

3. Updates and Corrections, Access.

If you register to use Website services, or to provide us with your Personally Identifiable Information, we ask that you keep information we maintain about you and your Organization on our systems, such as your name, email address, and other contact information, complete, accurate and up to date. You may update and access your Personally Identifiable Information by contacting us at www.shomagroup.com.
 

4.No Direct Marketing.

We will not rent, sell or license your Personally Identifiable Information or Personal Information to other organizations for their use in direct marketing to you. Notwithstanding the above, we may use and/or disclose to our agents your Personally Identifiable Information to contact you about our website and new features of the website, as well as new services offered by Shoma Group and our business partners.
 

5. Links to Other Websites and Services.

From time to time, this website may contain links to other websites. These other websites are not governed by this Privacy Policy, and we caution you to review, agree with and make sure you feel comfortable with that particular website’s own Privacy Policy, should you be transferred to, or go to yourself, before using that website or providing any information to its operators.
 

6.User Locations.

This Website is intended to be used only by users located within the continental United States, Alaska and Hawaii.
 

7.Security.

We will use reasonable security measures to protect the website and information gathered from you through use of this website and, at the least, those security measures required by law. However, we are not responsible for any breach of security or for the unauthorized use of your information by others.
 

8.Other Sources of Information About You.

This Privacy Policy governs only information gathered from you through this website. It does not govern information gathered from you through other means.
 

9. Monitor Your Use.

Shoma Group reserves the right to monitor your use of the website at any time, without notice.
 

10. Updates to Privacy Policy.

We reserve the right to change this Privacy Policy at any time and at our discretion. At the end of this policy we will post a summary of any material changes, including any changes that we make in the Privacy Policy which give us broader rights to use or disclose your Personally Identifiable Information for marketing purposes, and the effective date of such change. We will send a notice to the most recent e-mail address that you have given to us — if you have provided us with one — and will post a notice on the Website for at least 30 days, providing a mechanism through which you may opt out of application of the revised Privacy Policy to your previously gathered Personally Identifiable Information. With this mechanism, you will be given a time frame — usually 30 days — to exercise the Opt-Out option. If you continue to use the Website after the effective date of the change, the revised Privacy Policy will apply to any information we gather from you through the Website from that point on. If you do not opt out with respect to previously gathered Personally Identifiable Information through the mechanism we provide, and in the time frame provided, then that information, and any additional information gathered from you through the Website after the effective date of the change, will also be governed by the revised Privacy Policy.
 

11. Questions.

If you have any questions about this Website and its operations, please contact us at: www.shomagroup.com.
 
Shoma Group Is Committed to Protecting
The Privacy of client Information

● We use proven information security safeguards.
● We employ safeguards designed to protect the confidentiality of each client’s Records, client Accounts from information systems.
● We secure all protected information, utilize progressive technology and enforce regulatory mandates to limit access to information systems for client privacy.
● We ensure client Information is protected and secure.
● We protect the transfer of protected information between approved submitters and receivers.
● We hold ourselves accountable to our Privacy principles
● We established a Regulatory and Compliance Committee to ensure that the corporate culture of high ethics is continually emphasized. The committee structure includes representation from all business units and provides a forum for communication, discussion of topics essential to an effective compliance program and assurance that policies address the needs of the company.
● We also conduct internal and external assessments of our operational security and privacy practices.
● We provide all Shoma Group employees with Training Programs designed to educate them about the meaning, requirements and responsibilities of our Privacy practices and procedures. Employees who violate our Privacy guidelines and mandates are subject to disciplinary action, up to and including dismissal. Employees are expected to report any violations to their manager or to the Shoma Group Privacy Officer.
● We extend these Privacy principles to our partners.
● We require companies we select as our partners to agree to keep client Information confidential and secure.
● Our partners must also protect client Information against unauthorized access, use or disclosure by the partner, and limit its use to the purposes for which it was accessed.