ShortPoint Privacy Policy

ShortPoint Websites Privacy Policy

Owner and Data Controller

ShortPoint Inc is the owner of www.shortpoint.com and demos.shortpoint.com, jobs.shortpoint.com and all subdomains of shortpoint.com websites. Our address is 1327 JONES DRIVE, ANN ARBOR MI 48105 USA.

Owner contact email: privacy@shortpoint.com

Types of Data collected

Among the types of Personal Data that ShortPoint collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name; last name; phone number; profession; state; country; city; address; company name; Data communicated while using the service; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); ZIP/Postal code; workplace; website; number of employees; billing address; answers to questions; clicks; keypress events; mouse movements; scroll position; touch events.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using ShortPoint.

Unless specified otherwise, all Data requested by ShortPoint is mandatory and failure to provide this Data may make it impossible for ShortPoint to provide its services. In cases where ShortPoint specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by ShortPoint or by the owners of third-party services used by ShortPoint serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through ShortPoint and confirm that they have the third party's consent to provide the Data to the Owner.

ShortPoint is not intended to offer any services directly to children. Owner does not knowingly collect any information from children. However, if user is under the age of 16 and wants to get in touch with ShortPoint, they shall send the Owner a written consent from their parents or guardians to process their personal data.

Mode and place of processing the Data

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of ShortPoint (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;

• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

• processing is necessary for compliance with a legal obligation to which the Owner is subject;

• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

Where a User or their organization has enabled the ShortPoint AI Designer feature, the processing of prompt text, AI-generated replies, and associated session metadata is carried out on the following legal basis under GDPR Article 6:

• Article 6(1)(b) - Processing is necessary for the performance of the service agreement between ShortPoint and the customer who has activated the AI Designer feature. Prompt data and AI replies are processed solely to deliver the AI-generated page design functionality contracted by the customer.

• Article 6(1)(f) - Processing is necessary for the purposes of the legitimate interests pursued by the Owner, specifically to maintain billing records (token usage), provide customer support, and ensure system integrity. These interests are not overridden by the data subject's interests given the minimal nature of the metadata retained.

Tenant administrators may disable prompt and reply retention at any time using the Data Collection toggle in the ShortPoint Dashboard. When Data Collection is disabled, the legal basis for retaining prompt content no longer applies and such content is not stored.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. A transfer to recipients outside the EU only takes place if it is ensured that the recipient of the data guarantees an adequate level of data protection and that there are no other interests worthy of protection against the data transfer. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The following specific retention rules apply to data processed through the ShortPoint AI Designer feature:

• Prompt text and AI-generated replies are retained only when the tenant administrator has enabled the Data Collection setting in the ShortPoint Dashboard. When Data Collection is disabled, no new prompt or reply content will be stored from that point forward. To request deletion of any previously stored data, administrators may contact privacy@shortpoint.com.

• When Data Collection is disabled by the tenant administrator, no prompt text, AI-generated replies, tool-call data, or telemetry traces are stored. Only structural metadata required for billing purposes (token counts, session identifiers, timestamps) is retained.

• SharePoint and Microsoft Graph API data fetched by the user's authenticated browser during AI page generation is processed in memory only for the duration of that generation request. This data is never written to long-term storage and is discarded immediately upon completion of the response.

• Suspended generation context data (stored temporarily when an agent pauses to await browser-side Microsoft Graph API calls) is retained for a maximum of one (1) hour, after which it is automatically and permanently deleted.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Remarketing and behavioral targeting, Interaction with external social networks and platforms, Analytics, Managing contacts and sending messages, Contacting the User, Displaying content from external platforms, Tag Management, Advertising, Managing support and contact requests, Content performance and features testing (A/B testing), Traffic optimization and distribution, Registration and authentication provided directly by ShortPoint, User database management, SPAM protection, Interaction with data collection platforms and other third parties and Hosting and backend infrastructure.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

• Be informed. Users have the right to be informed on how their personal data is used.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Changes to Privacy Policy

This privacy Policy may be amended from time to time. The new version will come into force upon its publishing on the website of ShortPoint Inc. User may always find out whether the Privacy Policy was amended by checking “last modified” legend on the top of the page.

Cookie Policy

ShortPoint uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of ShortPoint or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, ShortPoint may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, ShortPoint and any third-party services may collect files that record interaction with ShortPoint (System logs) using other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within ShortPoint and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through ShortPoint (or third-party services employed in ShortPoint), which can include: the IP addresses or domain names of the computers utilized by the Users who use ShortPoint, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using ShortPoint who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of ShortPoint. The Data Controller, unless otherwise specified, is the Owner of ShortPoint.

Service

The service provided by ShortPoint as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

Last Updated: June 2, 2026