Jurisdiction-specific requirements are addressed in Appendix A below.
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 may automatically collect some information about you and your visit, such as 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 wish to disable the storage of cookies on your computer, you may do so by using the settings on your browser or device. Please note, however, that without cookies, you may not be able to use all the features of our Sites.
If you exchange emails, telephone conversations or other electronic communications with our employees and other staff members, our information technology systems may 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.
In addition to the information listed above, if you are a candidate for an advertised or referred position, or a prospective interested party for a non-specific role, and apply for a position at Scale Facilitation®, a background check may be initiated, and, we may collect the following types of personal information, among others, to the extent permitted by applicable law: Social Security number; national identifier or other government-issued identification number; driver’s license number; date of birth; address history; employment and education history; citizenship and work authorization status; and results of background checks.
Providing personal information to us is voluntary on your part. However, if you choose not to provide us with information we deem to be mandatory, such as where the data is required by law or under the terms of a contract we have with you, we may not be able to offer you certain of our products or services, and you may not be able to access certain features of our Sites.
In connection with operating our business and marketing our products and services, to the extent permitted by applicable law, we may obtain personal information from our related entities, regulatory or government authorities, industry bodies, professional associations and other 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.
We may also use the personal information we obtain in other ways for which we provide specific notice at the time of collection.
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, 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 for example Google Analytics, which may provide you with choices about how they collect and use information. As described above, we share certain 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
We may share your information with our affiliates and / 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 may also disclose information about you: (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) to law enforcement authorities or other government entities based on a lawful disclosure request; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent harm or financial loss; (5) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (6) with your consent. We reserve the right to transfer personal information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, spin-off, dissolution or liquidation).
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 data[at]scalefacilitation.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 the age of 18, and minors under the age of 16 may not use the Sites.
We do not knowingly solicit or collect personal information on the Sites from children under the age of 16. If we learn that, despite these measures, a child under the age of 16 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).
If you believe a child under the age of 16 may have provided us with personal information through the Sites, please contact us at data[at]scalefacilitation.com.
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. Our application response to such signals is dependent on the browser in use.
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 contacting us at data[at]scalefacilitation.com or using other unsubscribe features that we may 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, please contact us at data[at]scalefacilitation.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 data[at]scalefacilitation.com. 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. Where is information processed?
Information collected via the Sites may be processed and/or stored in data centers located in the United States of America, Ireland and Israel, and are subject to the laws of these countries, respectively – this may not provide the same level of protection for your information as your home country. The information may be available to the government or government agencies under a lawful order made in these countries. In addition, we may transfer your information to our affiliates, business partners, and service providers located in other countries.
K. 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 fulfill 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.
This policy is effective from February 24, 2023.
M. 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 data[at]scalefacilitation.com.
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 data[at]scalefacilitation.com.
Additionally, the California Consumer Privacy Act (“CCPA”) provides California residents with certain rights regarding their personal information. If you are a California resident, you have the right to request that we disclose to you or delete certain information about our collection and use of your personal information. Once we receive your request and verify your identity, we will disclose such information to you or delete the same, unless a legal exception applies.
Should you wish to provide your information anonymously or through a pseudo name, Scale Facilitation® may be limited in the services they can provide to meet the regulatory obligations.
Scale Facilitation® may use your information for direct marketing purposes. By providing your personal information, where direct marketing is sent to you, you will be provided with an option to opt out.
When you provide your personal information to Scale Facilitation®, you are acknowledging and agreeing that your personal information may be transferred between related bodies corporate, third parties who supply products and services to Scale Facilitation® and its affiliated entities.
These related bodies corporate, third parties or related entities to whom your personal information may be transferred, may be registered and governed by laws outside Australian jurisdictions. As such, the laws regulating a related body corporate may differ to Australian laws and may apply a greater or lesser standard of protection for personal information.
Should Scale Facilitation® transfer your personal information to a jurisdiction with inadequate privacy protection (e.g., such protection does not provide a level of protection equivalent to Australian privacy regulation), Scale Facilitation® will take reasonable steps to ensure that the relevant overseas recipient does not breach the Privacy Act. Alternatively, Scale Facilitation® may seek your consent to the transfer.
If you discover that your personal information is outdated, incorrect or incomplete, you can ask that it be corrected by contacting us at data[at]scalefacilitation.com.
Scale Facilitation® will respond to your request within a reasonable time frame. There is no charge to access your personal information, however, we may request you meet the reasonable costs in providing you with copies and/or access to your information.
You can also contact our Compliance Team if you have any questions about our compliance with Privacy Act or if you have a complaint about how we have handled your personal information. Please lodge any complaints in writing to compliance[at]scalefacilitation.com or posted to:
One World Trade Center
New York, NY 10007
Scale Facilitation will aim to respond within thirty days.
If you are unhappy with our response, you may lodge a complaint with the Office of the Australian Information Commissioner using the privacy complaint form on its website (www.oaic.gov.au).