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Effective Date: June 30, 2023
Collectively, we refer to the above as our “Services.” Additional or different privacy notices may apply to certain of our Services. If a different or supplemental privacy notice applies, this will be disclosed to you.
California Residents: See the California Privacy Rights section below for important information about your personal information and rights under applicable state privacy laws.
Categories of Personal Information We Collect
The type of information that we collect depends on your interaction and relationship with us. For example, personal information may be collected when you fill out a ‘Contact Us’ form on our Site or otherwise provide us personal information through the Site and Services. We collect, and in the preceding 12 months have collected, the below categories and types of personal information with your consent or as otherwise required or permitted by law.
- Identifiers, such as your name, email address, current and prior address, Internet Protocol (“IP”) address, account name, telephone number, business contact information, and title/position.
- Characteristics of Protected Classifications, such as your racial or ethnic origin, race, and gender.
- Commercial Information, such as records of products or services purchased, obtained, or considered and purchasing histories by you on behalf of the business(es) you represent in connection with our Services.
- Internet or Other Electronic Network Activity Information, such as your website interaction history, IP address, a date/time stamp, browser type, device type, device ID, Internet service provider, referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, and similar device and usage information.
- Audio/Visual Data or Similar Information, such as security camera footage and voicemails.
- Professional or Employment Information, such as information related to your employment history, including your resume.
- Education Information, such as your education history, degrees, transcripts, qualifications and certifications.
Sources Of Personal Information
We collect, and in the preceding 12 months have collected, personal information in the following ways:
- Directly from you. We collect identifiers, characteristics of protected classifications, commercial information, audio/visual data, professional or employment information, and education information that you provide directly to us.
- When you visit our locations. When you visit our offices or facilities, we also collect identifiers and audio/visual data.
- Automatically. When you access our Site, we may collect internet or electronic usage data using tools like functional cookies.
- From third parties. We may collect identifiers, characteristics of protected classifications, commercial information, professional or employment information, and education information from third-parties including our business contacts, vendors, customers, recruiters, suppliers, and service providers.
- From our employees or job applicants. We collect identifiers, characteristics of protected classifications, commercial information, professional or employment information, and education information from our current or former job applicants, contractors, and employees.
Purposes for Collecting Personal Information
We use personal information for the following business and commercial purposes:
- Recruiting and Hiring. We use identifiers, characteristics of protected classifications, professional or employment information, and education information during the recruitment process to evaluate an applicant or prospective applicant’s qualifications and eligibility for employment.
- Providing our Services. We use identifiers, commercial information, audio/visual data, and professional and employment information to facilitate the generation of new business opportunities, to allow customers to contract for and purchase our Services, to provide the products and Services we have contracted for, and to provide updates and reports requested by customers.
- Transactional Purposes. We use identifiers, professional or employment information, and commercial information to: (i) communicate with you; (ii) provide you with customer assistance; (iii) administer contracts with our vendors, customers, suppliers, and service providers; and (iv) provide supporting business activities such as billing and collections, and procurement related activities.
- Business Operations. We use identifiers, characteristics of protected classifications, commercial information, audio/visual data, professional or employment information, education information, and internet or other electronic network activity information, for our day-to-day business operations including maintaining records, managing and securing our facilities, planning, budgeting, calibration, headcount, database administration, surveys, evaluations, reports, compliance, regulatory, audit, investigative purposes and other ethics and compliance reporting tools, and to support our business operations.
- Marketing and Promotional Purposes. We use identifiers, professional or employment information, and commercial information to improve our marketing efforts, conduct market research, prospect for new clients, engage in client relationship management, client engagement, administering promotions, and to provide you with information about us, including personalized marketing communications.
- Maintenance and Improvement of our Site and Systems. We use identifiers and internet or other electronic network activity information to improve our Site and systems, provide and maintain functionality on our Site and systems, and help us diagnose technical and service problems and administer our Site and systems. Maintenance of our systems includes activities such as applying security controls for company systems, providing new system implementations, applying change management processes, and providing IT support services.
- Develop and Improve Our Services. We use commercial information to help us develop new products and services and to improve and analyze our existing service offerings.
- Security and Fraud Prevention. We use identifiers, characteristics of protected classifications, commercial information, internet or other electronic network activity information, audio/visual data, professional or employment information, and education information to: (i) protect us, our employees, and our Site, premises, assets, systems, products, services and intellectual property, including from fraud, theft, and misconduct; (ii) enforce our policies and terms; (iii) conduct vendor and customer due diligence; and (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.
- Complying with Legal and Ethical Obligations and Legal Process. We use identifiers, characteristics of protected classifications, commercial information, internet or other electronic network activity information, audio/visual data, professional or employment information, and education information to comply with our legal obligations, including responding to CCPA requests, reporting requirements and responding to court orders, warrants, or subpoenas, defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.
How We Disclose Personal Information
We disclose personal information in the following circumstances:
- Service Providers. We may share personal information with vendors and service providers who support the operation of our Services, Site, and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting, order fulfillment, email delivery, recruitment, marketing, insurance, operating systems and platforms, transportation, and customer support services). In some cases, the vendor or service provider may directly collect the information from you on our behalf. In the past 12 months, we have disclosed identifiers, professional or employment information, and education information, to our service providers.
- Professional Advisors. We may share information with professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of the professional services that they render to us. In the past 12 months, we have disclosed identifiers, characteristics of protected classifications, commercial information, internet or other electronic network activity information, audio/visual data, professional or employment information, and education information to our professional advisors.
- Government Entities. We share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us. In the past 12 months, we have disclosed personal information to government entities where required as part of regulatory filings and legal proceedings.
- Corporate Transaction Recipients. We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations; or (iii) are soliciting or accepting investments.
- Other Reasons. We may disclose personal information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information.
Sensitive Personal Information
Unless specifically requested, we ask that you not send us, and you not disclose to us, through the Services or otherwise, any Sensitive Personal Information (e.g., social security number, taxpayer identification number, passport number, driver’s license number, or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, or information on other judicial or administrative proceedings).
How Long We Keep Personal Information
We will retain and use your information for as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Where we process personal information for marketing purposes, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We use the following criteria to determine retention periods:
- how long the information is needed to provide our services and operate our business;
- whether there are contractual or legal obligations that exist that require us to retain the information for period of time;
- whether any law, statute, or regulation allows for a specific retention period;
- whether an individual has agreed to a longer retention period;
- whether the data is considered to be sensitive data; and
- what the expectation for retention was at the time the data was provided to us.
Links to Other Websites
We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.
This Website is Not Intended for Minors
Our Site is not intended for use by individuals under the age of 16. We do not knowingly collect or store any personal information from anyone under the age of 16. If we become aware that we have collected or stored personal information from an individual under age 16, we will remove their personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us by sending an email to Privacy@SCNBestco.com.
Marketing Emails. You may request to opt out of marketing or advertising emails by contacting us at Privacy@SCNBestco.com. Once we process your request, we will cease using the information for such purposes at no charge to you. If you opt out of getting marketing messages, you will continue to receive messages from us about your relationship with us where permitted by law.
Processing in the United States
California Privacy Rights
If you are a California resident, this section applies to you.
Shine The Light. The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third-parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at Privacy@SCNBestco.com and include “CA Shine the Light” in the subject line of your email. We do not currently disclose your personal information to third parties for their own direct marketing purposes.
California Consumer Privacy Act (“CCPA”), as Amended by the California Privacy Rights Act (“CPRA”).
Sale or Sharing of Personal Information. In the preceding 12 months, we have not “sold” or “shared” (as those terms are defined in the CCPA) any personal information to “third parties”, as that term is defined in the CCPA. We do not knowingly sell or share the personal information of minors under the age of 16.
Use or Disclosure of Sensitive Personal Information. The following forms of data listed above constitutes “sensitive personal information”: your race, racial or ethnic origin. We do not use or disclose sensitive personal information for any purpose other than those permitted by the CCPA and its interpretive regulations.
Your Rights Under the CCPA. Subject to certain exceptions and limitations, the CCPA affords California consumers the following rights:
- You have the right to request that we tell you (i) what personal information we have collected about you, (ii) the sources of that information, (iii) the purposes for collecting, selling or sharing the personal information; and (iv) the categories of third-parties to whom we have disclosed personal information.
- You have the right to request that we provide you with a copy of your personal information.
- You have the right to request that we delete personal information that we have collected from you. We may not delete all of your personal information if one of the exceptions to the CCPA applies.
- You have the right to correct inaccurate personal information that we hold about you.
- You have the right to not be discriminated against for exercising any of your CCPA rights. We will not discriminate against you, deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA rights.
Exercising Your Rights. To exercise any of your rights, please email us at Privacy@SCNBestco.com, call us toll free at 1-866-942-2429, or use the webform link on our site to submit a request. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. You can ask to appeal any denial of your request in the same manner through which you may submit a request.
For all requests, you should provide us with sufficient information to verify your identity and process your request. Failure to provide identifying information may prevent us from processing your request. If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.
Authorized Agents. Your authorized agent may be able to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.
If you have any questions about this Policy or our privacy practices, please email us at Privacy@SCNBestco.com