This privacy statement sets out the basis on which we will process any personal information that we may collect about you as a visitor to any of the Sites.
A. The types of information we collect:
1. Information that you provide
This is information about you that you provide by filling in forms on the Sites (or any other form you provide Scale Facilitation®), providing a business card (or similar), while attending a Scale Facilitation® related event or corresponding with Scale Facilitation® by telephone, post, email or otherwise. It may include, for example, your name, address, email address and telephone number; information about your business relationship with Scale Facilitation®; information about your professional role, background and interests; and information relating to events.
2. Information that our websites and other systems collect about you
If you visit our Sites they will automatically collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information such as your browser type and version and the pages on the sites that you visit.
If you exchange emails, telephone conversations or other electronic communications with our employees and other staff members, our information technology systems will record details of those conversations, sometimes including their content.
3. Other information
Our Sites may contain links to websites operated by third-parties, and your personal information may be collected by those third-parties when you use their websites.
Should you choose to visit these third-party sites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your information. We do not accept, and do disclaim, any responsibility for the privacy policies and information collection, use, and sharing practices of any third-party website (whether or not such site is linked on or to our Sites). These links are provided to you for convenience purposes only, and you access them at your own risk.
Some of our third-party partners may ask you to provide personal information on their websites and may share such personal information with us, as governed by their respective privacy policies.
We will link the information that we collect automatically with the information you provide us, and we will combine the information we collect online with information we collect offline or that is collected by third-parties.
B. How we use the information we collect:
We may use your information for particular purposes including the following
to operate, manage, develop and promote our business and, in particular, our relationship with you or the organization you represent (if any) and related transactions;
to send you emails containing marketing information which we believe you will find relevant and interesting;
to operate, administer and improve our websites and premises and other aspects of the way in which we conduct our operations;
to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes; and
to comply with our legal and regulatory obligations and bring and defend legal claims.
We may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you. For example, we may prepare aggregated reports about how visitors tend to interact with the Sites for research about the use of the Sites and how the Sites could be improved, from which your interactions with the Sites cannot be singled out.
C. How we share the information we collect:
1. In connection with third party offers
We may share information about you with third-parties when you engage in certain activities on the Sites that are sponsored by third-parties. For example, you may choose to purchase products or services offered by a third-party or elect to receive information or communications from a third-party. If you engage in such third-party offerings, we may share information (e.g., your e-mail address) with third-parties in association with the offerings.
We disclose this information to third-parties for the purposes and on the basis described above (see Section B), for example, to process your transactions and to respond to your requests for information or communications from third-parties.
2. Service providers
Sometimes we engage companies that act on our behalf in association with the operation of the Sites. For example, such companies may deliver products or services, improve the functionality of the Sites, collect information about you, communicate with you, or store information for us. In some cases, these companies may need to access information about you.
3. Analytics providers
The third-party services we use include, but may not be limited to: Google Analytics and Adobe, which may provide you with choices about how they collect and use information. As described above, we share personal information with analytics providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business.
4. Additional Sharing Practices
From time to time we share your information with our affiliates or with our attorneys, banks, auditors and other service providers in connection with the purposes described above. From time to time, we partner with other organizations or companies to provide co-sponsored or co-branded promotions, services, or events, and we will share your information with our co-sponsor(s) and partners to the extent necessary for the partnership to function.
Additionally, we reserve the right to share with third-parties information that does not identify you (and cannot be combined with other information accessible to us to identify you) for any purpose.
We do not sell your personal information and have never done so previously.
D. The security measures we take to safeguard information:
The security and confidentiality of the information we collect or receive is extremely important to us, and we take our responsibility to protect this information very seriously. We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. From time to time, we review and consider updates for our security procedures. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.
E. Updating your contact information:
You may update your contact information and/or modify your communication preferences by sending us an e-mail at email@example.com. Additionally, we may provide tools on the Sites that facilitate such updates or modifications.
F. Children’s information:
The Sites are intended for use by those over 18, and minors under the age of 13 may not use the Sites.
We do not knowingly solicit or collect personal information on the Sites from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted personally identifiable information to us through the Site, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).
G. Do not track:
Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals.
Third-parties, such as our analytics providers, may collect data that relates to you on the Sites, across time, and over other websites. We cannot control third-parties’ responses to do-not-track signals or other such mechanisms. Third-parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.
H. Your choices and rights:
If you no longer wish to receive marketing materials from us, you can let us know by clicking here or contacting us at firstname.lastname@example.org or using other unsubscribe features that we provide in our marketing communications.
Subject to local law, you may have certain additional rights regarding your personal information.
These may include the following rights to: access your personal information; rectify the information we hold about you; erase your personal information; restrict our use of your personal information; object to our use of your personal information (as described above); receive your personal information in a usable electronic format and transmit it to a third-party (also known as the right of data portability); and lodge a complaint with your local data protection authority, and withdraw any consent you have given to uses of your personal information. If you would like to discuss or exercise the rights you may have, feel free to contact us at email@example.com.
We will not discriminate against you for exercising any of these rights, for example, by charging a different price or denying goods or services.
I. How to exercise data subject rights:
If you would like to discuss or exercise the rights you may have, contact us at firstname.lastname@example.org. We will review your request and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard.
If you make a request related to your rights, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, we may require additional proof of identification.
If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.
We will process your request within the time provided by applicable law.
J. Shine the Light disclosures:
If you are a California resident, you have the right to request certain information from us regarding the manner in which we share with third-parties certain categories of information that identifies you for the third-parties’ direct marketing purposes. If you wish to exercise this right, please email us at email@example.com. For additional information about your rights under the CCPA and how to exercise those rights, refer to “Your Choices and Rights” in Section H above.
K. Where is information processed?
We process information collected via the Sites in and subject to the laws of the United States, which may not provide the same level of protection for your information as your home country. The information may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries.
L. How long is information retained?
We retain your personal information for as long as we have a relationship with you and for a period after our relationship with you has ended.
When deciding how long to keep your personal information after our relationship with you has ended, we take into account how long we need to retain the information to fulfil the purposes described above and to comply with our legal obligations. We may also retain personal information to investigate or defend against potential legal claims in accordance with the limitation periods of jurisdictions where legal action may be brought.
M. CCPA categories of personal information collected
The CCPA requires us to provide additional information about the personal information we collect with reference to specific categories of information. For additional information about our sources of personal data, how we use personal data, and how we disclose personal data, refer to Sections A-C above.
This policy is effective from March 23, 2020.
O. How to contact us
If you have any questions regarding this policy or our privacy or data protection practices, please feel free to contact us at firstname.lastname@example.org.