Last updated: October 22, 2021
You must be at least 18 years old to use www.scalablecommerce.com (the “Site”). Scalable Commerce, LLC, its subsidiaries and affiliated companies, and each of their respective officers, directors, members, owners, employees, agents, and representatives are included in any reference to the “Site”, “Us”, and/or “We” herein.
Personal Information We Collect About You
We collect, use, and are responsible for certain personal information about you, that identifies, relates to, describes, is reasonably capable of being associated with you, or that which could reasonably be linked, directly or indirectly, with a particular consumer or household. We collect, and have collected personal information about Our visitors within the preceding 12 months in the following categories and for the noted purposes:
|Categories of Personal Information||Collected?||Categories of Sources from Which PI is Collected||Business or Commercial Purpose for Which Each Category Will be Used|
|Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers||Yes||Site, including any job applications submitted through the Site||
|Any categories of personal information described in subdivision (e) of Sec. 1798.80||Yes||Site, including any job applications submitted through the Site||
|Characteristics of protected classifications under California or federal law||Yes||Site, including any job applications submitted through the Site||
|Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||No||N/A||N/A|
|Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement||Yes||Site||
|Audio, electronic, visual, thermal, olfactory, or similar information||No||N/A||N/A|
|Professional or employment-related information||Yes||Site, including any job applications submitted through the Site||
|Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)||No||N/A||N/A|
|Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No||N/A||N/A|
As noted in the above chart, We collect the above personal information directly from you via the Site, and from your interactions with the Site, including any personal information which you provide directly or indirectly.
Through the Site: We collect any personal information which you submit directly to the Site, including but not limited to any requests, job application(s), or communications submitted to Us through the Site.
Cookies and Tracking Pixels on the Site: We collect the above personal information directly from you via the Site, including from cookies on the Site. We use and store cookies and tracking pixels on the Site, as described further, to facilitate and customize your use of our Site. A cookie is a small data text file, which is stored on your computer's hard drive (if your web browser permits) that can later be retrieved to identify you to Us. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies can later be retrieved to identify you to Us. Personal information that We store about you may be linked to the information stored in and obtained from cookies. Cookies make your use of the Site easier, make the Site run more smoothly, and help Us to maintain a secure Site. Tracking pixels (also known as web beacons, 1×1 pixels, or clear GIFs) are code requiring a call back to a server to render, and which deliver information to Us about your IP address and information from your browser. Cookies and tracking pixels are used to track your interaction with the Site. Cookies and tracking pixels may collect information about you, such as your IP address, your browser type and version, operating system, software and platform, your Internet service provider, geographic location, the area code and zip code associated with your server, time zone setting, the date and time of your visit, the time spent on the Site, screen resolutions, color capabilities, browser plug-ins, language settings, and cookie preferences.
How We Use Collected Personal Information
We use information collected through your use of the Site to provide you with the ability to access and interact with the Site; track your access and interaction with the Site; fulfill requests submitted through the Site; personalize and improve the Site; supplement our internal database; statistically analyze and monitor Site use; detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity; debug to identify and repair errors that affect functionality of the Site; and to comply with all applicable laws, regulations, and related requests.
Further, to the extent that you apply for a job through the Site, We use the information to review and make hiring decisions, including but not limited to process and evaluate your application, and communicate with you regarding your application.
As noted above, in the event that your web browser requests that We do not track you or store a cookie, unless otherwise required by law to do so, We do not guarantee that our Site will honor such requests.
With Whom Do We Share Your Information
We may share the above information internally with our subsidiaries and affiliated companies. Also, on occasion, We may be required by law enforcement or judicial authorities to provide information to the appropriate governmental authorities. In the event of a merger, acquisition, or sale of our business, your information may also be transferred. In the event that We become the subject of an insolvency proceeding, whether voluntary or involuntary, We or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such information in a transaction approved by the court.
The security of your data is important to Us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect your data, We cannot guarantee its absolute security. As a result, you acknowledge that there are security and privacy limitations of the Internet which are beyond our control; the security, integrity, and privacy of any and all information and data exchanged between you and Us through this Site cannot be guaranteed; and any such information and data may be viewed or tampered with in transit by a third party. We make no warranty, express, implied, or otherwise, regarding the security of the Site and your personal information.
You must be an adult of 18 years or older to use the Site. Consistent with the federal Children’s Online Privacy Protection Act of 1998 (“COPPA”), We will never knowingly collect personal information from anyone under the age of 13 without requesting parental consent. If you are aware that your minor child under the age of 13 has provided Us with personal information, please contact Us.
California Residents – Your Privacy Rights
California Rights Under the CCPA
In addition, if you are a California resident under the meaning of Sec. 17014 of Title 18 of the Cal. Code of Regulations, your use of the Site is subject to the California Consumer Privacy Act (“CCPA”), and all final, implementing regulations. Under the CCPA, up to twice in a twelve (12) month period, a consumer has the right to request that a business disclose what personal information it collects, uses, discloses, and sells. Information regarding Our collection and disclosure practices are detailed herein, in addition to instructions on how to exercise your rights regarding your personal information.
What Personal Information Do We Collect?
We collect, use, and are responsible for certain personal information about you, that identifies, relates to, describes, is reasonably capable of being associated with you, or that which could reasonably be linked, directly or indirectly, with a particular consumer or household. Information on the personal information that We collect, and have collected about Our visitors within the preceding 12 months are detailed above under the “Personal Information We Collect About You” heading.
What Personal Information Do We Disclose?
We may also disclose your personal information in any of the above categories if legally required to do so, in Our sole discretion, pursuant to a request from a governmental entity, or if We believe in good faith that such action is necessary to (a) conform to legal requirements or comply with legal process; (b) protect Our rights or property, or Our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public. Also, in the event that We, or substantially all of Our assets, are acquired, personal information in the above noted categories may be included within the transferred assets. In the event We become the subject of an insolvency proceeding, whether voluntary or involuntary, We or Our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such personal information in the above noted categories in a transaction approved by the court.
What Personal Information Do We Sell?
Under the definitions of “Sell” and “Sale” in the CCPA, We do not sell your personal information. We do not have any actual knowledge of the sale of personal information of minors under 16 years of age. There are no financial incentives to disclose.
Your Right to Request to Know and How to Submit a Verified Request to Know
A “request to know” is a request related to the personal information that a business has about such consumer. It may include a request for any or all of the following from Us:
- specific pieces of personal information that We have collected about you;
- categories of personal information that We have collected about you;
- categories of sources from which the personal information was collected;
- categories of personal information that We have sold or disclosed for a business purpose about you;
- categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling personal information.
The CCPA permits requests to know from the same consumer up to twice in a twelve (12) month period.
To submit a request to know, please email Us at [email protected] To process your request, We may require that you submit the following information in conjunction with your request: your first name, last name, a California address, and email address. The information which you provide will be used to verify your request and to attempt to identify you within Our data records. If you elect to use an authorized agent to exercise your right to submit a request for information, We may require that the authorized agent provide proof that the consumer gave them signed permission to submit the request. In addition, We may also require that the consumer directly verify their identity and directly confirm that they provided the authorized agent permission to submit the request on their behalf. The information which is submitted in conjunction with the request to know will be used for the express purposes of verification and providing responsive information to the request, if required.
Your Right to Request Deletion and How to Submit a Verified Request to Delete
You have the right to request the deletion of any personal information which We have collected about you. To submit a verifiable request to delete, please email Us at [email protected], or contact Us by mail at 3905 State Street Suite 7-228, Santa Barbara, CA 93105. To process your request, We may require that you submit the following information in conjunction with your request: your first name, last name, a California address, and email address. The information which you provide will be used to verify your request and to attempt to identify you within Our data records. If you elect to use an authorized agent to exercise your right to submit a request for deletion, We may require that the authorized agent provide proof that the consumer gave them signed permission to submit the request. In addition, We may also require that the consumer directly verify their identity and directly confirm that they provided the authorized agent permission to submit the request on their behalf. The information which you submit in conjunction with your request to delete will be used for the express purposes of verification and fulfilling your request, if required. The information which is submitted in conjunction with the request to delete will be used for the express purposes of verification and fulfilling the request, if required.
We utilize a two-step process for online requests to delete, whereby you first submit your request to delete, and second, you separately confirm that you want your personal information deleted.
To the extent that your personal information is necessary for Us to maintain for a reason delineated in Cal. Civ. Code Sec. 1798.105(d), including but not limited to complete a transaction for which the personal information was collected, provide a good or service you have requested, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, debug, etc., or to comply with a legal obligation, We are not required to comply with your request for deletion. For instance, We are not required to delete personal information which is necessary to maintain suppression files for those individuals who have opted out of receiving email marketing from Us. If We are unable to verify your request, We will notify you as well.
“Shine the Light”
We do not disclose personal information to third parties for their direct marketing purposes.
Your Right to Non-Discrimination for the Exercise of Your Privacy Rights
California affords consumers with the right not to receive discriminatory treatment by a business for the exercise of their privacy rights conferred by the CCPA. This means that you cannot be denied goods or services; be charged different prices or rates; be provided with a different level or quality of goods or services; or have it suggested that you will receive a different price or rate or different level or quality of goods or services. However, a business may offer a financial incentive or price or service difference if it is reasonably related to the value of the consumer’s data. A business shall notify consumers of any financial incentive or price or service difference.
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