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Privacy Policy

 

Privileged & Confidential

Privacy Notice

Last Updated: 04.25.23

SCS Consultants Limited, Inc. (“SCS Consultants Limited”, “we”, “our” or “us”) is committed to protecting the privacy of Personal Data.

This Privacy Notice describes how we process Personal Data collected through our websites, emails,

social media accounts, and other digital properties, and through other online and offline interactions

(collectively, the “Services”). All capitalized terms used but not defined in this Privacy Notice have the

meanings assigned to them in the Terms of Use.

Some of the Services we provide to you might be on behalf of our Practitioners or other third parties. In

this role, we are what some privacy laws refer to as a "processor" or "service provider.” When we handle

Personal Data in our capacity as a service provider to Practitioners or other third parties, we are bound

by contractual obligations and this Privacy Policy does not apply. We do not control and are not

responsible for the privacy and data collection practices of the Practitioners or other third parties, and

you should ask them if you have questions about such practices. This Privacy Notice also does not apply

to the data about our own employees, contractors, agents, and job applicants.

We may update this Privacy Notice from time to time. Any updated Privacy Notice will be effective when

posted. Please check this Privacy Notice periodically for updates. If required by law, we will contact you

directly to provide you with an updated Privacy Notice.

1. Sources of Personal Data

“Personal Data” is data that identifies, relates to, describes, is reasonably capable of being associated

with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Personal Data does not include publicly available information, de-identified or aggregated information,

or information covered by certain federal and state laws.

We collect Personal Data about you from the following sources:

• Directly from you. We may collect Personal Data you provide to us directly, such as when you

contact us through the Services, interact with us in person, sign up for offers or newsletters,

communicate with us, place or customize orders, or sign up for an account or other services.

• Data collected automatically and through tracking technologies. We may automatically collect

information or inferences about you, such as through cookies and other tracking technologies,

when you interact with the Services. This may include information about how you use and

interact with the Services or otherwise interact with us, information about your device, and

internet usage information.

• From third parties. We may collect Personal Data from third parties, such as Practitioners,

service and content providers, business partners, our affiliated companies and subsidiaries,

business partners, and social media companies or other parties who interact with us.

• From publicly available sources. We may collect Personal Data about you from publicly

available sources, such as public profiles and websites.

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We may combine and use information and make inferences from information that we receive from the

various sources described in this Privacy Notice, including third party sources. We may also use or

disclose the combined information and inferences for the purposes identified below.

2. Types of Personal Data We Collect

We may collect the following types of Personal Data:

• Identifiers, such as your name, email address, physical address, telephone number, business

contact information, account number, and device identifiers (e.g., cookie IDs and IP address).

• Records about you, such as preference information (including marketing and purchasing

preferences), account settings (including any default preferences), the content, timing and

method of communications you have with us, such as online chats, calls, and emails, signatures

and physical characteristics or a description of you.

• Protected class and demographic information, such as age (including birthdates) and gender.

• Commercial information, such as purchase or subscription information, information about

products you order or are interested in, payment details, delivery details, and other commercial

or financial information; and legal information relating to your transactions, such as fraud checks

or flags raised about your transactions, payment card refusals, complaints and information

related to their resolution, and legal requests and communications.

• Internet or other electronic network activity information, such as your browsing history, search

history, and other information regarding your interactions with and use of the Services. For more

information about cookies and other device data, please see the Cookies and Other Tracking

Technologies section.

• Non-precise geolocation data, such as your approximate location based on your IP address.

• Audio, electronic, visual, or other sensory information, such as photographs taken at events,

call recordings, and video recordings.

• Inferences drawn from any of the information we collect to assess the level of interest in our

products and services based on frequency of visits and contact.

3. How We Use Personal Data

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We may use Personal Data for the following purposes:

• To provide you products and services, such as facilitating interactions with Practitioners and

providing and delivering you the other goods and services you request, providing customer

service; processing or fulfilling orders and transactions, verifying customer information;

processing payments; communicating with you about your product, service or subscription;

hosting informational webinars; verifying eligibility for certain programs or benefits; responding

to requests, complaints, and inquiries; and providing similar services or otherwise facilitating

your relationship with us.

• For our internal business purposes, such as maintaining or servicing accounts; operating the

Services and customizing the content; maintaining internal business records; enforcing our

policies and rules; conducting organizational analysis; completing management reporting;

managing our assets and global workforce; undertaking work planning, both administratively

and organizationally (including work schedules and billing of clients); project management;

auditing; maintaining records on business activities; IT administration of our network, intranet,

and other technologies; and IT security management and tasks.

• For our internal research and product improvement purposes, such as verifying or maintaining

the quality or safety of our products or services; improving our products or services; designing

new products and services; evaluating the effectiveness of our advertising or marketing efforts;

and debugging and repairing errors with our systems, networks, and equipment.

• For legal, safety or security reasons, such as complying with legal requirements, processes, or

orders; fulfilling reporting and similar requirements; complying with government inspections and

other requests from government or other public authorities; pursuing legal rights and remedies;

investigating and responding to claims against us and our customers and employees; protecting

our, your, our customers’, and other individuals’ safety, property or rights; addressing security

and health and safety issues (including managing spread of communicable diseases) and

malicious, deceptive, fraudulent, or illegal activity; and receiving legal advice or approval.

• In connection with a corporate transaction, such as if we acquire, or some or all of our assets

are acquired by, another entity, including through a sale in connection with bankruptcy and

other forms of corporate change.

• For marketing and targeted advertising, such as marketing our products or services. For

example, we and our business partners may use Personal Data we collect to personalize

advertising to you on this website or others, to analyze interactions with our email

communications or website areas viewed, to develop product, brand or services audiences

(including by identifying you across devices/sites) to better target our advertising to you, or to

send you newsletters, surveys, questionnaires, promotions, or information about events or

webinars. You can unsubscribe to our email marketing via the link in the email or by contacting

us using the information in Section 9 (Contact Information) below.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

4. How We Disclose Personal Data

We may disclose Personal Data to third parties, including the categories of recipients described below:

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• Service providers that work on our behalf to provide the products and services you request or

support our relationship with you, such as IT providers, internet service providers, web hosting

providers, data analytics providers, and companies that provide business support services,

financial administration, or event organization.

• Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.

• Vendors necessary to complete transactions you request, such as shipping companies and

logistics providers.

• Law enforcement, government agencies, and other recipients for legal, security, or safety

purposes, such as when we share information to comply with law or legal requirements, to

enforce or apply our Terms of Use and other agreements or policies, and to protect our, your,

our customers’, or other third parties' safety, property, or rights.

• Other entities in connection with a corporate transaction, such as if we, or some or all of our

assets, are acquired by another entity, including through a sale in connection with bankruptcy or

other forms of corporate change.

• Business partners that may use Personal Data for their own purposes, such as companies that

operate cookies and other tracking technologies, social media companies, marketing and

advertising partners, and other business partners for their own marketing, research, or analytics

purposes. Where required by law, we will obtain your consent prior to disclosing your Personal

Data to our business partners. Where recipients use your Personal Data for their own purposes

independently from us, we are not responsible for their privacy practices or personal data

processing policies. You should consult the privacy notices of those third-party services for

details on their practices.

• Entities to which you have consented to the disclosure.

5. Cookies and Other Tracking Technologies

The Services and authorized third parties may use cookies and other tracking technologies to collect

information about you, your device, and how you interact with the Services. This section contains

additional information about:

• The types of tracking technologies we use and the purposes for which we use them

• The types of information we collect using these technologies

• How we disclose or make information available to others

• Choices you may have regarding these technologies

Types of cookies and tracking technologies we use

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We and the third parties that we authorize may use the following tracking technologies:

• Cookies, which are a type of technology that install a small amount of information on a user's

computer or other device when they visit a website. Some cookies exist only during a single session

and some are persistent over multiple sessions over time.

• Pixels, web beacons, and tags, which are types of code or transparent graphics. In addition to the

uses described below, these technologies provide analytical information about the user experience

and help us customize our marketing activities. In contrast to cookies, which are stored on a user's

computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages.

Purposes for using these technologies

We and authorized third parties use these technologies for purposes including:

• Personalization, such as remembering language preferences and pages and products you have

viewed in order to enhance and personalize your experience when you visit the Services;

• Improving performance, such as maintaining and improving the performance of the Services;

• Analytics, such as analyzing how our websites are used. For example, we use Google Analytics to

help us improve the user experience. Google Analytics may use cookies and other tracking

technologies to perform their services. To learn how Google Analytics collects and processes

data, please visit: “How Google uses data when you use our partners’ sites or apps” located at

www.google.com/policies/privacy/partners;

• Advertising, such as conducting advertising and content personalization on the Services and

those of third parties; tracking activity over time and across properties to develop a profile of

your interests and advertise to you based on those interests (“interest-based advertising”);

providing you with offers and online content that may be of interest to you; and measuring the

effectiveness of advertising campaigns and our communications with you, including identifying

how and when you engage with one of our emails; and

• Security, such as preventing fraud and malicious behavior.

Information collected using these technologies

These tracking technologies collect data about you and your device, such as your IP address, location

(both approximate and precise) cookie ID, device ID, Ad ID, operating system, browser used, browser

history, search history, and information about how you interact with the Services (such as pages on the

Services that you have viewed).

Disclosures of your information collected through these technologies

We may disclose information to third parties or allow third parties to directly collect information using

these technologies on the Services, such as social media companies, advertising networks, companies

that provide analytics including ad tracking and reporting, security providers, and others that help us

operate our business and the Services.

Your choices

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Some of the third parties we work with participate with the Digital Advertising Alliance ("DAA") and

Network Advertising Initiative ("NAI"). The DAA and NAI provide mechanisms for you to opt out of

interest-based advertising performed by participating members at http://www.aboutads.info/choices/

and https://optout.networkadvertising.org/. We adhere to the DAA’s Self-Regulatory Principles for

Online Behavioral Advertising. You may also click on the AboutAds icon on a Company advertisement

and follow the instructions on how to opt out.

You can also refuse or delete cookies using your browser settings. If you refuse or delete cookies, some

of the Services’ functionality may be impaired. Please refer to your browser’s Help instructions to learn

more about how to manage cookies and the use of other tracking technologies. If you change

computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies,

you may need to repeat this process for each computer, device, or browser. Opting out of interest-based

advertising will not opt you out of all advertising, but rather only interest-based advertising from us or

our agents or representatives.

Some browsers have incorporated Do Not Track (“DNT”) preferences. At this time, we do not honor Do

Not Track signals.

6. Data Security and Data Retention

We maintain reasonable security procedures and technical and organizational measures to protect your

Personal Data against accidental or unlawful destruction, loss, disclosure or use. However, no data

transmission over the internet is ever 100% secure and, we cannot guarantee or warrant the security of

any information you transmit to our Services.

Your Personal Data will be retained as long as necessary to fulfill the purposes we have outlined above

unless we are required to do otherwise by applicable law. This includes retaining your Personal Data to

provide you with the products or services you have requested and interact with you; maintain our

business relationship with you; improve our business over time; ensure the ongoing legality, safety and

security of our services and relationships; or otherwise in accordance with our internal retention

procedures. Once you have terminated your relationship with us, we may retain your Personal Data in

our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated

contracts or for other legitimate business purposes.

7. External Links

The Services may contain links to external sites or other online services that we do not control, including

those embedded in third party advertisements or sponsor information. We are not responsible for the

privacy practices or data collection policies of such third-party services. You should consult the privacy

notices of those third-party services for details on their practices.

8. International Transfers

If you are located outside of the United States and provide Personal Data to us, your Personal Data will

be transferred to the United States, where data protection laws may differ from those of your home

country. By providing us with your Personal Data, you acknowledge that your Personal Data will be

transferred to the United States and processed on servers in the United States. If you do not want to

have you Personal Data transferred and processed in the United States, please do not submit it us.

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9. Contact Information

If you have questions regarding this Privacy Notice, please contact us by email at info@scsalesconsulting.com.

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