This Privacy Notice is designed to help you understand how “Scale” (“we,” “us,” or“our”) collects, uses, and shares your personal information (also known as personal data), and to help you understand and exercise your privacy rights.

This Privacy Notice applies to personal information processed by us, including on our websites and other online or offline offerings that link to this Privacy Notice. To make this Privacy Notice easier to read, our websites and other offerings are collectively called the “Services.”

Scale provides a hosted data processing platform (“Platform Services”) to our customers (“Customers”) and their authorized personnel (“Authorized Users”) under the Scale Terms of Service and, with respect to Scale Endpoints. This Privacy Notice does not apply to (i) Customer Data (as defined in the Platform Agreement); or (ii) any products, services, websites, or content that are offered by third parties or that have their own privacy notice. Our Customers’ respective privacy policies govern their collection and use of Customer Data. Any questions or requests relating to Customer Data should be directed to our customer.

1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice and/or may also send other communications.

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

• Account Information. We may collect personal information in connection with the creation or administration of your account, such as your name, email address, phone number, and any other information that you provide to us or that we otherwise collect.
• Submissions. We may collect personal information in connection with any submissions or queries you make via the Scale Platform Services (which submissions and queries are considered 'Customer Data' under the Platform Agreement).
• Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
• Your Communications with Us. We may collect personal information, such as your name, email address, or phone number when you contact us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging or chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered public. Please exercise care when deciding what to share.
• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use our Services.

• Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, items that you search for via the Services and the results returned, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. We may also use the information we collect automatically (for example, IP address, and unique device identifiers) to identify the same unique person across the Services to provide a more seamless and personalized experience to you.
• Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services. The types of data collection tools we use may change over time as technology evolves. An example of a few types of tools are noted below:
  • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

C. Personal Information Collected from Other Sources

We may obtain information about you from third party sources, including resellers, distributors, business partners, event sponsors, security and fraud detection services, social media platforms, and publicly available sources. Examples of information that we receive from third parties include marketing and sales information (such as name, email address, phone number and similar contact information), and purchase, support and other information about your interactions with our Services. We may combine such information with the information we receive and collect from you.

3. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services

We use your personal information to fulfill our contract with you and provide, maintain, improve and update our Services, such as:

• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support;
• Communicating with you about your account, activities on our Services, and policy changes;
• Processing your financial information and other payment methods for products or Services purchased;
• Processing applications if you apply for a job at Scale;
• Allowing you to register for events.

B. Administrative Purposes

We use your personal information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services;
• Improving, upgrading, or enhancing our Services;
• Carrying out analytics;
• Developing new products and services;
• Creating de-identified and/or aggregated information;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing personal information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

D. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

E. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your personal information are described below.

• Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with analytics, IT support, hosting, payment processing, customer service, and related services.
• Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”). If you do, the information you share will be subject to the Third-Party Service’s terms and privacy policy. We are not responsible for Third-Party Services.
• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
• Affiliates. We may share your personal information with our corporate affiliates.
• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising”, “personalized advertising”, or “targeted advertising.”

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to this Privacy Notice).
• Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.
• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs may not be effective on mobile applications and you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict or object to our uses of your personal information; (v) seek correction or amendment of your personal information; (vi) withdraw your consent; and (vii) request erasure of your personal information, subject to certain exceptions prescribed by law.

Scale may take certain steps to verify your request using information available to us, such as your email address or other information associated with your Scale account, and if needed we may ask you to provide additional information for the purposes of verifying your request. Any information you provide to us for verification purposes will only be used to process and maintain a record of your request. We will process such requests in accordance with applicable laws. As described above, we may also process personal information that has been submitted by a Customer to our Platform Services. If your personal information has been submitted to the Platform Services by or on behalf of a Scale Customer and you wish to exercise your privacy rights, please direct your request to the relevant Customer. If you would like to exercise any of the rights described above or for other inquiries, please contact us as set forth in “Contact Us” below.

If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

7. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Notice for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

8. SUPPLEMENTAL NOTICE FOR EU/UK GDPR

This Supplemental Notice for EU/UK GDPR only applies to our processing of personal information that is subject to the EU or UK GDPR.

Scale’s processing of your personal information may be supported by one or more of the following legal bases:

• Performance of a Contract: Scale may need to process your personal information to perform our contract with you.
• Legitimate Interest: Scale may process your personal information to further our legitimate interests, but only where our interests are not overridden by your interests or fundamental rights and freedoms.
• Consent: In some cases, Scale may also rely on your consent to process your personal information.
• Compliance with our Legal Obligations: Scale may process your personal information to comply with our legal obligations.

9. NOTICE TO AUTHORIZED USERS

Our Platform Services are intended to be used by organizations. Where the Platform Services are made available to you through an organization (e.g., your employer), that organization is the administrator of the Platform Services and responsible for the accounts and/or services over which it has control. For example, administrators can access and change information in your account or restrict and terminate your access to the Platform Services. We are not responsible for the privacy or security practices of an administrator's organization, which may be different from this Privacy Notice. Please contact your organization or refer to your organization's policies for more information.

10. THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

12. CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at: info@scale.com.