PRIVACY POLICY. We and our service providers may collect and combine Personal Information about you from a variety of sources, including:

Transcription

1 PRIVACY POLICY Scala Pr, Inc., is respnsible fr the use and prtectin f yur persnal infrmatin, and therefre we prvide yu with the fllwing infrmatin: Scpe. This Privacy Plicy applies t persnal infrmatin cllected nline, used and disclsed by Scala Pr, Inc. (cllectively referred t as Scala Pr ) in cnnectin with its websites, micrsites, mbile sites r mbile apps that expressly adpt, display r link t this Privacy Plicy (cllectively referred t as ur Sites ). It als applies t persnal infrmatin we cllect, use and disclse in cnnectin with Scala Pr pages n scial media sites, such as Facebk, Twitter, Ggle Plus r thers (cllectively referred t as ur Scial Media Pages ). NOTE: Scala Pr licenses the use f its trademarks t unrelated third parties which perate websites independently frm Scala Pr. This Privacy Plicy des nt cver the websites f these third parties. These third parties have separate and independent privacy plicies which we recmmend yu read carefully. This Privacy Plicy answers the fllwing questins: 1. What infrmatin des Scala Pr cllect abut yu? 2. Hw d we use the Persnal Infrmatin we cllect abut yu? 3. Des Scala Pr share yur infrmatin with third parties? 4. What Other Infrmatin abut yu des Scala Pr cllect? 5. What chices d yu have ver hw Scala Pr uses and disclses yur Persnal Infrmatin? 6. Hw des Scala Pr secure yur Persnal infrmatin? 7. Hw can yu access, change, r delete yur Persnal Infrmatin? 8. Third party services 9. Retentin perid 10. Use f services by minrs 11. Third party payment services 12. Will this Privacy Plicy change? 13. Hw can I cntact Scala Pr? 1. What infrmatin des Scala Pr cllect abut yu? Persnal Infrmatin is infrmatin that identifies yu as an individual r relates t an identifiable individual. We and ur service prviders may cllect and cmbine Persnal Infrmatin abut yu frm a variety f surces, including: Thrugh the Services, fr example, when yu sign up fr a newsletter, marketing s and ther cmmercial electrnic messages (e.g., n upcming prmtins, new prducts, etc.), register an accunt t access the Services (e.g. t register yur prducts, t ask fr supprt, t participate in ur cntests r cmpetitins, t make inquiries regarding prduct warranties), r make a purchase, r thrugh ur Scial Media Pages. Frm Other Surces. We receive yur Persnal Infrmatin frm ther surces, fr example: Publicly available databases, such as LinkedIn r lcal Trade r Industrial Assciatins registries. Jint marketing partners, when they share the infrmatin with us, including: privately held marketing r survey / enquiry databases. If yu cnnect yur scial media accunt t yur Services accunt, yu will share certain Persnal Infrmatin frm yur scial media accunt with us, fr example, yur name, address, pht, list f scial media cntacts, and any ther infrmatin that may be 1.

2 r yu make accessible t us when yu cnnect yur scial media accunt t yur Services accunt, depending n the preferences / chices yu have selected within yur scial media accunt s setting, r the pinins expressed (e.g., Likes ) yu have prvided within ur Scial Media pages. We generally cllect the fllwing types f Persnal Infrmatin: Yur Name Mailing address address Birthdate Telephne number Mbile phne number Pstal/zip cde, state/prvince, and cuntry Username and passwrd (related t yur accunt) Purchase, rder infrmatin and payment details Demgraphic infrmatin (fr example number f husehld members, cuntry f residence, age and gender) Infrmatin related t custmer satisfactin surveys, custmer requests r queries Purchasing habits and ther infrmatin, including registratin f prducts purchased Interests and hbbies Infrmatin n prducts yu want, like r wn Bank infrmatin (e.g. fr special ffers reimbursement, warranty extensin, prizes r cntests) On certain Sites, we allw yu t use yur persnal scial media accunt, n scial media sites ( Persnal Scial Media Accunt ), t prvide Persnal Infrmatin t us when yu participate in certain features n ur Sites. This Persnal Infrmatin may include the fllwing: Yur name and/r nickname Prfile picture Gender Netwrks User id 2.

3 List f friends and related cntact details Language Vice recrdings Vide and phtgraphs Birthday Educatin Wrk histry/prfessin Address Interests/Hbbies Likes r nline grup membership Cuntry Opinins expressed (e.g. when replying arund the satisfactin abut ne f ur prducts) It is als pssible that we will be able t cntinue cllecting this infrmatin frm yur Persnal Scial Media Accunts shuld the infrmatin be revised by yu later. We need t cllect Persnal Infrmatin in rder t prvide the requested Services t yu. Yu may chse nt t prvide us with certain requested infrmatin, but then yu might nt be able t take advantage f sme f ur Service features r we may nt be able t prvide yu with the Services. If yu disclse any Persnal Infrmatin relating t ther peple t us r t ur service prviders in cnnectin with the Services, yu represent that yu have the authrity t d s and t permit us t use the infrmatin in accrdance with this Privacy Plicy. 2. Hw d we use the infrmatin we cllect abut yu? The Persnal Infrmatin we cllect frm yu helps us persnalize yur experience with us and ur cmmunicatins t yu and helps us cntinually imprve yur experience with ur Services. We and ur service prviders use the Persnal Infrmatin cllected abve fr the fllwing purpses including: Prviding the functinality f the Services and fulfilling yur requests, including: Opening and arranging access t yur registered accunt. Respnding t yur inquiries and fulfilling yur requests fr example when yu cntact us via ne f ur nline cntact frms r chat lines. Prcessing yur rder r ther transactins, including warranty and prduct registratin, claim, r request, and prviding related custmer service. 3.

4 T send administrative infrmatin t yu, such as changes t ur terms, cnditins and plicies. T allw yu t send messages t anther persn if yu chse t d s. We will engage in these activities t manage ur cntractual relatinship with yu, and/r t take steps at yur request prir t entering int a cntract, and/r t cmply with a legal bligatin. Prviding yu with ur newsletter and/r ther marketing materials and facilitating scial sharing. T send yu advertising and marketing related s, text messages, and pstal mail with infrmatin abut ur services, new prducts and ther news abut ur cmpany. T facilitate scial sharing functinality that yu chse t use. T send wish lists r ther s n yur behalf. We will engage in this activity with yur cnsent. Analysis f Persnal Infrmatin fr business reprting and prviding persnalized services. T better understand yu, s that we can persnalize yur experiences when using ur Services and prvide yu with infrmatin and/r ffers tailred t yur interests. T better understand yur preferences s that we can deliver cntent via ur Services that we believe will be relevant and interesting t yu. T analyze r predict ur users preferences in rder t prepare aggregated trend reprts n hw ur digital cntent is used and perfrm market research, s we can imprve ur Services. We will prvide persnalized services either with yur cnsent r because we have a legitimate interest. Allwing yu t participate in sweepstakes, cntests r ther prmtins. We may ffer yu the pprtunity t participate in a sweepstakes, cntest r ther prmtin. Sme f these prmtins have additinal rules cntaining infrmatin abut hw we will use and disclse yur Persnal Infrmatin. We use this infrmatin t manage ur cntractual relatinship with yu. Aggregating and/r annymizing Persnal Infrmatin. We may aggregate and/r annymize Persnal Infrmatin s that it will n lnger be cnsidered Persnal Infrmatin. We d s t generate ther data fr ur use, which we may use and disclse fr any purpse. Accmplishing ur business purpses. 4.

5 Fr data analysis, fr example, t imprve the efficiency f ur Services. Fr audits, t verify that ur internal prcesses functin as intended and are cmpliant with legal, regulatry r cntractual requirements. Fr fraud and security mnitring purpses, fr example, t detect and prevent cyberattacks r attempts t cmmit identity theft. Fr imprving and develping ur prducts and services. Fr enhancing, imprving, r mdifying ur current prducts and services. Fr identifying usage trends, fr example, understanding which parts f ur Services are f mst interest t users. Fr facilitating recalls. Fr prcessing jb applicatins. Fr determining the effectiveness f ur prmtinal campaigns, s that we can adapt ur campaigns t the needs and interests f ur users. Fr perating and expanding ur business activities, fr example, understanding which parts f ur Services are f mst interest t ur users s we can fcus ur energies n meeting ur users interests. We engage in these activities t manage ur cntractual relatinship with yu, t cmply with a legal bligatin, and/r because we have a legitimate interest. 3. Des Scala Pr share yur infrmatin with third parties? We d nt sell, rent, r trade yur persnal infrmatin t unrelated third parties. We may share yur persnal infrmatin with the fllwing: ur affiliates and third-party service prviders in rder t perfrm tasks n ur behalf such as the fllwing: facilitating yur purchase assisting in servicing ur prducts helping yu exchange prducts prviding and imprving ur cmmunicatins with yu respnding t requests t ur investr relatins as required t cperate with a subpena, search warrant r ther legally valid inquiry, curt rder r ther legal prcess, r as required r permitted by law t prtect the rights, prperty r safety f ur Sites, ur users r thers, including where necessary fr the establishment, exercise r defense f legal claims. If Scala Pr were ever merged with r acquired by anther cmpany, r if we acquire anther business entity r are invlved in a crprate rerganizatin r ther change f cntrl, r if we sell substantially all the assets f a divisin, affiliate r subsidiary, sme r all f the persnal infrmatin cllected abut yu culd be shared with the acquiring r acquired cmpany. We may als share aggregate data abut ur sales, custmers, traffic patterns, and ther related Site infrmatin with third parties, but nne f this data is cnnected t an individual s persnal infrmatin. 5.

6 4. What ther infrmatin abut yu des Scala Pr cllect? Other Infrmatin is any infrmatin that des nt reveal yur specific identity r des nt directly relate t an identifiable individual. Other Infrmatin includes: Brwser type and versin Operating system IP Address (see belw fr further infrmatin) The Internet service prvider used t access ur Services Use f links t arrive at ur Services and the IP address frm which yu arrived Web pages requested and viewed Time spent n ur Services Fr ur mbile websites and apps, technical infrmatin abut the device used, such as screen size, ckie supprt by the device and hw images may appear App usage data Other infrmatin cllected thrugh ckies, pixel tags, and ther technlgies described belw Demgraphic infrmatin and ther infrmatin prvided by yu that des nt reveal yur specific identity Infrmatin that has been aggregated in a manner such that it n lnger reveals yur specific identity Yur IP address is autmatically assigned t yur cmputer by yur Internet Service Prvider. An IP address may be identified and lgged autmatically in ur server lg files whenever a user accesses the Services, alng with the time f the visit and the page(s) that were visited. Cllecting IP addresses is standard practice and is dne autmatically by many websites, applicatins and ther services. We use IP addresses fr purpses such as calculating usage levels, diagnsing server prblems and administering the Services. We may als derive yur apprximate lcatin frm yur IP address (see Lcatin belw). We may use and disclse Other Infrmatin fr any purpse, except where we are required t d therwise under applicable law. If we are required t treat Other Infrmatin as Persnal Infrmatin under applicable law, then we may use and disclse it fr the purpses fr which we use and disclse Persnal Infrmatin as detailed in this Plicy. We and ur service prviders cllect Other Infrmatin in a variety f ways, including: Thrugh yur brwser r device: Certain infrmatin is cllected by mst brwsers r autmatically thrugh yur device, such as yur Media Access Cntrl (MAC) address, cmputer type (Windws r Mac), screen reslutin, perating system name and versin, device manufacturer and mdel, language, Internet brwser type and versin and the name and versin f the Services 6.

7 (such as the Apps) yu are using. We use this infrmatin t ensure that the Services functin prperly. Thrugh yur use f the Apps When yu dwnlad and use the Apps, we and ur service prviders may track and cllect App usage data, such as the date and time the App n yur device accesses ur servers and what infrmatin and files have been dwnladed t the App based n yur device number. Physical Lcatin Infrmatin Our Services and HTML-frmatted s include features that may require cllecting different types f lcatin infrmatin (such as IP Address, GPS crdinates r pstal cde) that we then use fr the specific feature yu have selected, such as: . Our s use yur IP Address t determine the pstal cde where yu are lcated when yu pen the . This allws us t tailr cntent t yu, such as a map f nearby stres carrying ur prducts. The specificity f the lcatin can vary depending n the device used t pen ur s. Yur prgram may allw yu t prevent the pixel tags r images in the s yu receive frm us frm dwnlading, which will als prevent ur service prvider frm accessing yur lcatin infrmatin. Yu can als unsubscribe frm receiving ur s, by sending an t inf@scalaprs.cm. We may als share yur device s physical lcatin, cmbined with infrmatin abut what advertisements yu viewed and ther infrmatin we cllect, with ur marketing partners t enable them t prvide yu with mre persnalized cntent and t study the effectiveness f advertising campaigns. Ckies We and ur third-party service prviders use ckies. Ckies assign a unique identificatin t yur device and are typically stred directly n yur device by yur web brwser. The infrmatin we and ur third-party service prviders cllect thrugh ckies, pixel tags and similar technlgy includes the fllwing: Yur interactins with ur Services and with ur advertisements The time f yur visit t ur Services Items and prducts brwsed, items put int yur shpping cart, and whether yu purchase any r all f thse items Cnfirmatin when yu pen frm us, including the time yu pen the and whether yu click n any links in the Sites yu visit after visiting ne f ur Sites Language preferences 7.

8 Other traffic data We and ur service prviders use ckies fr: security purpses, t facilitate navigatin, t display infrmatin mre effectively, and t persnalize yur experience, t tailr marketing t yu based n yur use f the Services, determine return visitrs, keep track f items in yur cart, and serving tailred ads n ther sites, as described belw. We als gather statistical infrmatin abut use f the Services in rder t cntinually imprve their design and functinality, t imprve and better transact business, t understand hw Services are used, measure which parts f ur Sites are mst visited r used, mnitring the number f visitrs t ur Sites, and assist us with reslving questins regarding the Services. Ckies further allw us t select which f ur advertisements r ffers are mst likely t appeal t yu and display them while yu are n the Services and n ther sites. We may als use ckies r ther technlgies in nline advertising t track respnses t ur ads and measure the effectiveness f ur advertising. Our systems may nt recgnize D Nt Track headers frm sme r all brwsers. If yu d nt want infrmatin cllected thrugh the use f ckies, mst brwsers allw yu t autmatically decline ckies r be given the chice f declining r accepting a particular ckie (r ckies) frm a particular website. Yu may als wish t refer t If, hwever, yu d nt accept ckies, yu may experience sme incnvenience in yur use f the Services. Yu als may nt receive advertising r ther ffers frm us that are relevant t yur interests and needs. Pixel tags and ther similar technlgies We may als use pixel tags (als knwn as web beacns, web bugs, and clear GIFs) in prviding the Services. A pixel tag is a nearly invisible pixel-sized graphic image n a webpage r in an message. We use these technlgies t, amng ther things, track the actins f users f the Services (including recipients), measure the success f ur marketing campaigns, measure which parts f ur Sites are mst visited r used, and cmpile statistics abut usage f the Services and respnse rates. Third-party analytics We use third-party analytics prviders, such as Ggle Analytics, which uses ckies and similar technlgies t measure traffic and usage trends, and t help us better understand yur use f and interactin with ur Services. This service may als cllect infrmatin regarding the use f ther websites, apps and nline resurces. Fr mre infrmatin n hw Ggle uses data when yu use ur Services, click here, and pt ut f Ggle s practices by dwnlading the Ggle Analytics pt-ut brwser add-n, available here. Other Infrmatin frm Scial Media Pages Similar t the navigatinal infrmatin described abve, the scial media sites where we have ur Scial Media Pages may prvide aggregate infrmatin and analysis t us abut visitrs t ur Scial Media Pages. This allws us t better understand and analyze ur user grwth, general demgraphic infrmatin abut the users f, and interactin with cntent n, ur Scial Media Pages. 8.

9 Using Adbe Flash technlgy (including Flash Lcal Shared Objects ( Flash LSOs )) and ther similar technlgies We may use Flash LSOs and ther technlgies t, amng ther things, cllect and stre infrmatin abut yur use f the Services. If yu d nt want Flash LSOs stred n yur cmputer, yu can adjust the settings f yur Flash player t blck Flash LSO strage using the tls cntained in the Website Strage Settings Panel. Yu can als g t the Glbal Strage Settings Panel and fllw the instructins (which may explain, fr example, hw t delete existing Flash LSOs (referred t as infrmatin ), hw t prevent Flash LSOs frm being placed n yur cmputer withut yur being asked, and hw t blck Flash LSOs that are nt being delivered by the peratr f the page yu are n at the time). Please nte that setting the Flash Player t restrict r limit acceptance f Flash LSOs may reduce r impede the functinality f sme Flash applicatins. We additinally use Other Infrmatin gathered thrugh technlgy fr identifying and addressing difficulties visitrs may experience in accessing ur Services. 5. What chices d yu have ver hw we use and disclse yur Persnal Infrmatin? We give yu chices abut the infrmatin we cllect and hw we cmmunicate with yu and use and disclse yur infrmatin. a. Yu may pt-ut f ur marketing s by fllwing the instructins listed in the that yu received. Hwever, even if yu pt-ut yu may still receive nn-marketing s, such as rder/shipping cnfirmatins, changes t service, prduct registratins, prduct recalls r custmer service cmmunicatins. b. Text messaging/im: Yu may pt ut f mbile text messages (e.g., SMS, MMS) and ther instant messages (e.g., WhatsApp, Facebk Messenger) frm us, by fllwing the pt-ut instructins accmpanying such messages. d. Pstal Marketing: If yu n lnger want t receive marketing materials frm us via regular pstal mail, please cntact us at inf@scalaprs.cm and tell us that yu want t be remved frm the Scala Pr pstal mailing list, including the pstal address yu wish t have remved. e. Ckies: Yu may set yur web brwser t ntify yu when yu receive a ckie r t nt accept certain ckies. Hwever, if yu decide nt t accept ckies frm ur Services, yu may nt be able t take advantage f all f the features f ur Services. f. Our sharing f yur Persnal Infrmatin with affiliates fr their direct marketing purpses: If yu wuld prefer that we discntinue sharing yur Persnal Infrmatin n a gingfrward basis with ur affiliates fr their direct marketing purpses, yu may pt-ut f this sharing by cntacting us as at inf@scalaprs.cm. We will try t cmply with yur request(s) as sn as reasnably practicable. Please nte that if yu ptut f receiving marketing-related s frm us, we may still send yu imprtant administrative messages, frm which yu cannt pt-ut. 6. Hw des Scala Pr secure yur infrmatin n its Sites? If yu are using ne f ur Sites with an nline stre, we designed ur nline stre t accept rders nly frm Web brwsers that permit cmmunicatin thrugh Secure Scket Layer (SSL) technlgy, which encrypts yur infrmatin while it is being transmitted t us. Brwsers that d nt meet this requirement will be prevented frm navigating the nline stre sectin f ur Sites. We als use firewalls and have implemented ther reasnable technical, administrative and physical measures designed t prtect the 9.

10 persnal infrmatin in ur custdy r cntrl frm unauthrized access, use, mdificatin and disclsure. While we implement the abve security measures n ur Websites, yu shuld be aware that 100% security is nt always pssible. 7. Hw can yu access, change r delete yur Persnal Infrmatin? If yu wuld like t request t access, update, crrect, suppress, restrict, r delete Persnal Infrmatin previusly prvided t us, bject t the prcessing f Persnal Infrmatin, r if yu wuld like t request t receive an electrnic cpy f yur Persnal Infrmatin fr purpses f transmitting it t anther cmpany (t the extent this right t data prtability is prvided t yu by applicable law), yu can d this by ing us at inf@scalaprs.cm. In yur request, please make clear what Persnal Infrmatin yu wuld like t have changed, whether yu wuld like t have yur Persnal Infrmatin suppressed frm ur database r therwise let us knw what limitatins yu wuld like t put n ur use f yur Persnal Infrmatin. Fr yur prtectin, we may nly implement requests with respect t the Persnal Infrmatin assciated with the particular address that yu use t send us yur request, and we may request certain Persnal Infrmatin fr the purpses f verifying the identity f the individual seeking access t their Persnal Infrmatin recrds. We will try t cmply with yur request as sn as reasnably practicable. Please nte that we may need t retain certain infrmatin fr recrdkeeping purpses and/r t cmplete any transactins that yu began prir t requesting a change r deletin (e.g., when yu make a purchase r enter a prmtin, yu may nt be able t change r delete the Persnal Infrmatin prvided until after the cmpletin f such purchase r prmtin). Yu may als access, update and crrect inaccuracies in certain Persnal Infrmatin thrugh yur accunt fr certain Services. 8. Third party services Scala Pr licenses the use f its trademarks t unrelated third parties which perate websites independently frm Scala Pr. This Privacy Plicy des nt cver the privacy, infrmatin, r ther practices f any third parties, including any third party perating any website r service t which the Services link, including any third-party website r service n which Scala Pr maintains its Scial Media Pages. These third parties have separate and independent privacy plicies which we recmmend yu read carefully. The inclusin f a link n the Services des nt imply endrsement f the linked site r service by us r by ur affiliates. In additin, we are nt respnsible fr the infrmatin cllectin, use, disclsure r security plicies r practices f ther rganizatins, such as Facebk, Twitter, Ggle, r any ther app develper, app prvider, scial media platfrm prvider, perating system prvider, wireless service prvider r device manufacturer, including with respect t any Persnal Infrmatin yu disclse t ther rganizatins thrugh r in cnnectin with the Apps r ur Scial Media Pages. 9. Retentin perid We retain Persnal Infrmatin fr as lng as needed r permitted in light f the purpse(s) fr which it was btained and cnsistent with applicable law. The criteria used t determine ur retentin perids include: The length f time we have an nging relatinship with yu and prvide the Services t yu (fr example, fr as lng as yu have an accunt with us r keep using the Services); Whether there is a legal bligatin t which we are subject (fr example, certain laws require us t keep recrds f yur transactins fr a certain perid f time befre we can delete them); r 10.

11 Whether retentin is advisable in light f ur legal psitin (such as in regard t applicable statutes f limitatins, litigatin r regulatry investigatins). Please nte that where yu unsubscribe frm ur marketing cmmunicatins, we will keep a recrd f yur address t ensure we d nt send yu marketing s in the future. 10. Use f services by minrs The Services are nt directed t individuals under the age f eighteen (18), and we d nt knwingly cllect Persnal Infrmatin frm individuals under Third party payment services We may use a third-party payment service t prcess payments made thrugh the Services. If yu wish t make a payment thrugh the Services, yur Persnal Infrmatin will be cllected by such third party and nt by us and will be subject t the third party s privacy plicy, rather than this Privacy Plicy. We have n cntrl ver, and are nt respnsible fr, this third party s cllectin, use and disclsure f yur Persnal Infrmatin. 12. Will this Privacy Plicy change? We may make changes t this Privacy Plicy at any time, s please review it peridically. We will update the effective date f the Privacy Plicy at the time a change is made. Yur use f the Services fllwing these changes means that yu accept the revised Privacy Plicy. 13. Hw can I cntact Scala Pr? If yu have questins r cncerns with respect t ur Privacy Plicy, please cntact the Privacy Plicy Manager by sending an t: inf@scalaprs.cm and include yur questin. This Privacy Plicy is effective: Dec