Effective: October 26, 2018
Please read this Policy carefully so that you understand what information Scalable Path collects and how Scalable Path uses it. This Policy applies to all users, regardless of whether the user registers an account.
Our commitment to your privacy, is based on the following principles which we apply to our use of personally identifiable data we collect or that you provide to us ("Your Data"). As used herein, "Your Data" includes all information included in the definition of "personal information", "personal data" and all similar terms used in the "Data Protection Laws" (as defined below).
- We will describe Your Data we will collect;
- We will inform you clearly about our collection and use of Your Data;
- We will either seek your express informed consent or tell you about any other lawful bases for the use of Your Data;
- We will give you control over the privacy preferences that apply to Your Data, including the rights to (a) change your mind about our use, (b) have access to change or correct inaccurate parts of Your Data, and (c) require that we delete all or parts of Your Data;
- We will not sell or rent Your Data to others;
- We will do our best to maximize the protection of Your Data, and provide you with prompt notice in the unlikely event that a data loss incident or breach occurs;
- We will act in a manner that is consistent with and as required by all laws applicable to our possession and use of Your Data, including state and national law and relevant international law such as the European Union General Data Protection Regulation (the "GDPR" and together with all other relevant data protection law and regulation, the "Data Protection Laws");
- We will try to be completely transparent and open about our data privacy policies and practices.
Section 1 – What information Scalable Path collects
Your Data collected by Scalable Path includes the following information:
To access certain features of the Site (e.g., to create a profile or to track ongoing projects), you must create an account. When you create or edit this account, Scalable Path collects the personal information that you submit during that process, such as your name and your email address. We will ask for your consent to use this information to help you use the features and functionality of your account and to provide the services and capabilities of your account.
Scalable Path receives information you provide if you participate in questionnaires, surveys, or contests when visiting the Site. Participation in these events is voluntary and you therefore have a choice whether to disclose the requested information. If you choose to participate, the Scalable Path will use this information to determine winners, award prizes, and to manage the activity, as applicable. We will tell you about any other use when you register for or participate in the activity.
Section 2 – Use and disclosure of your data
General Uses. Scalable Path does not use Your Data without a legal or lawful basis which Scalable Path will identify either in this Policy or at the time of collection.. In addition to the uses described elsewhere in this Policy, Scalable Path uses Your Data for the following purposes:
- To create user accounts, to provide the Site and related services and features and to otherwise meet our obligations to you whether or not under a formal written agreement (including connecting clients with designers, developers, and other contractors);
- To operate, customize, develop, analyze, and improve the Site (including related services and features);
- To understand your preferences to enhance your experience with the Site;
- To respond to your comments and questions;
- To provide and deliver the products, services, and information that you request;
- To send you information related to the Site, including confirmations, receipts, technical notices, updates, security alerts, and support and administrative messages.
- To diagnose and fix technology problems;
- To combine your information with other information that Scalable Path gets from third parties to help understand your preferences, to provide you with better services, and to help determine demographic and interest attributes about users.
Lawful or Legal Basis/Sharing Your Data. We will only use Your Data in reliance on a valid legal basis for such use. Our goal and commitment is to inform you when we would like to use Your Data, the purposes for which we will use it and the legal basis for our use. We may ask for your express consent to the use of Your Data. There may be a contractual relationship between you and Scalable Path (the contract does not have to be in writing) where we need to use Your Data to provide you with the services you are entitled to under the agreement. We will tell you – either in this Policy or at the time of collection - when we are relying on our obligation to comply with our contractual obligations to you for the use of Your Data. Under some circumstances, we may rely on a “legitimate interest assessment” where we take into account your expectations about our use of Your Data and the limited way we will use Your Data, always seeking to maximize your privacy. When we rely on this approach, you have the right to tell us we cannot use Your Data in the ways we describe.
Scalable Path does not share Your Data with third parties, except as described in this Policy. Scalable Path may share your information in the following circumstances:
- Your Consent. Scalable Path may share Your Data with your express consent, such as when you authorize Scalable Path to send your information to a third party. When you create an account as a developer, designer, or contractor, you will be asked to consent to Scalable Path sharing your information with other users, such as current and potential clients.
- Service Providers. Scalable Path may share your information with third parties that provide services on our behalf, including services related to ad serving, analytics, and promotion management. Unless otherwise stated in this Policy, these service providers will be given access to Your Data only as is reasonably necessary to provide their services and under reasonable confidentiality terms. See the FAQ for a current list of these approved third-party vendors.
- Law and Harm. Scalable Path may preserve or disclose your information if it believes that it is reasonably necessary to comply with a law, regulation, or legal request; to protect the safety of any person or entity; to address or investigate fraud, security, or technical issues; or to protect Scalable Path's rights or property, or the rights or property of its employees, agents, contractors, or affiliated companies.
- Business Transfers. In the event that Scalable Path is involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of related transactions. The Policy will apply to Your Data as transferred to the new entity.
- Non-Private or Non-Personal Information. Scalable Path may share your non-private, aggregated, or non-personal information (such as your public user profile, information, public content, or the number of users who clicked on a particular link) with advertisers, publishers, business associates, sponsors, and other third parties.
Section 3 – Other websites and services
Certain links throughout the Site may direct you away from the Site. Scalable Path is not responsible for, and cannot control, the privacy practices of other sites and service providers. Once you leave the Site information subsequently collected is no longer governed by this Policy.
Section 4 – Commitment to data security
Scalable Path takes commercially reasonable and appropriate measures to protect Your Data from unauthorized access and against loss, misuse, and alteration by third parties. Although Scalable Path makes reasonable, good faith efforts to store the information collected through the Site in a private, secure operating environment, Scalable Path cannot guarantee its absolute security during its transmission or its storage. Further, while Scalable Path attempts to ensure the integrity and security of its network and systems, it cannot guarantee that its security measures will prevent third parties (e.g., “hackers”) from illegally accessing this information. While Scalable Path does not warrant that Your Data will be protected against loss, misuse, or alteration by third parties we will comply with all applicable Data Protection Laws in the event of a data security breach. No method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, Scalable Path cannot guarantee its security.
Section 5 – Commitment to children’s privacy
Scalable Path does not knowingly collect or solicit personal information from anyone under 13, or knowingly allow children under 13 to use, access, or register for the Site. If you are under 13, please do not send any information about yourself to Scalable Path. No one under the age of 13 may provide to Scalable Path any personal information. In the event that Scalable Path learns that it has collected personal information from a child under 13, Scalable Path will delete that information as quickly as reasonably possible. If you believe that Scalable Path might have any information from a child under 13, please contact us at firstname.lastname@example.org.
Section 6 – Do not track signals
Some web browsers offer a “Do No Track” (“DNT”) signal. A DNT signal is an HTTP header field indicating your preference regarding tracking or cross-site user tracking. Scalable Path does not respond to DNT signals. Scalable Path also works with third parties that use tracking technologies on the Site in order to provide tailored advertisements on Scalable Path’s behalf and on behalf of other advertisers across the Internet. These companies may collect information about your activity on the Site and your interaction with Scalable Path’s advertising and other communications, and use this information to determine which ads you see on third-party websites and applications.
Section 7 – Updating this policy
Scalable Path may revise this Policy to reflect changes to its information practices. The most current version will always be located here. If the revision, in Scalable Path’s reasonable judgement, is material, it will notify you via email to the email address associated with your account or by posting notice on the Site. As partial consideration for accessing or using the Site, you agree to check back here from time to time to determine if the Policy has been revised.
Section 8 – Modifying your data
You are responsible for maintaining the accuracy of any information you submit to Scalable Path. If Your Data changes, or if you no longer desire to use the Site, you may change or delete Your Data by editing your account settings or by contacting email@example.com. Scalable Path will respond to your request within 30 days.
Section 9 – Opting out of marketing
You may opt-out of receiving promotional emails from Scalable Path by following the instructions in those emails or by emailing firstname.lastname@example.org with your request. If you opt-out, Scalable Path may still send you non-promotional emails, such as emails regarding your account or providing information that you have specifically requested.
Section 10 – Data retention
Scalable Path will retain your information for as long as it has a valid lawful basis for doing so. If you wish to cancel your account or request that Scalable Path no longer use Your Data to provide you services, contact email@example.com. Scalable Path will retain and use Your Data only for so long as it has a lawful basis for doing so, including as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements.
Section 11 – Cross border transfers
If you visit our Site from a country other than the United States, your communications will likely result in the transfer of Your Data across national borders. Our servers or offices may be located in countries other than the country from which you access our Site, also resulting in the transfer of Your Data across international borders. If you provide Your Data when visiting our Site from outside of the United States, this data may be transferred from your then current location to our offices and servers and to those of our affiliates, agents, and service providers located in the United States and in other countries. The United States and such other countries may not have the same level of data protection as those that apply in the jurisdiction where you live. For Site visitors who reside in the European Economic Area, Switzerland or the United Kingdom, we will only transfer Your Data (a) to jurisdictions with “adequate protection” as used in the GDPR, or (b) to recipients with appropriate safeguards in place, including where contractual arrangements exist, which include Standard Contractual Clauses (as defined in the GDPR) without any additions, modifications, or omissions.
Section 12 - Compliance
Our collection and use of any of Your Data is subject to the Data Protection Laws applicable in the country or jurisdiction in which you reside or of which you are a citizen. We are and remain committed to complying with all applicable Data Protection Laws and use these legal requirements as the minimum beginning point for our use and collection of Your Data. Included in these laws and regulations are (a) the GDPR, which governs among other things, consents, uses and cross-border transfers of personal data concerning European Union residents and citizens, and (b) the California Online Privacy Protection Act, governing such matters with respect to California residents. If you have any questions regarding this Policy or you feel that the Site is not following these legal requirements or the Policy, please contact us by email to Policy firstname.lastname@example.org or at the address set forth above. You may also contact us at that address if you have any concerns about the accuracy of, or wish to correct, your Personal Data we have collected from you.
Section 13 – Your California privacy rights.
California Civil Code Section 1798.83 entitles California residents to request information, once a year, free of charge, concerning whether a business has disclosed Personal Data to any third parties for their direct marketing purposes. To make such a request, please send a request to the contact information below. As stated in this Policy, we will not sell your Personal Data to other companies and we will not share it with other companies for them to use for their own marketing purposes without your consent. For further information concerning your California Privacy Rights including “Do Not Track,” visit https://oag.ca.gov/sites/all/files/agweb/pdfs/cybersecurity/making_your_privacy_practices_public.pdf
California Web Site Data Collection
We do not knowingly allow other parties to collect personally identifiable information about your online activities over time and across third-party web sites when you use the Site. We provide information about the opt-out or opt-in choices available to users.
Section 14 – Contact information
If you have questions or comments regarding this Policy or our privacy practices, please contact:Scalable Path, Inc.
500 Westover Dr #9092
Sanford, NC 27330