Effective Date: August 31, 2023

Who Are We?
Scanbuy Inc., our subsidiaries and our affiliates (collectively, “Scanbuy,” “us, “we,” or “our”) help companies and organizations better understand and engage with consumers and markets by using digital technology to support mobile engagement campaigns. Scanbuy’s services empower companies to promote transparency, inspire action, and encourage lasting consumer loyalty. Scanbuy Site (the “Service”) delivers advanced mobile services that overcome the limits of time and space to help navigate every aspect of the customer journey. CPGs can rely on our SmartLabel™ services to turn their packages into marketing opportunities by instantly opening the door to everything consumers need to know about the products they use and consume, while brands and retailers team with Scanbuy to launch digital couponing services that drive in-store traffic, increase shopper baskets, and enhance the consumer experience. Scanbuy does not collect directly-identifiable data, such as names, email addresses, phone numbers, or social media user names from consumers in connection with our Service.

What Is the Scope of This Policy?
This Scanbuy Site Privacy Policy (the “Policy”) explains how Scanbuy collects, uses, and discloses personal information from and about our clients, prospective clients, and website visitors (each, referred to as “you”) when you use our websites and other online products and services (collectively, the “Site”).  This Policy applies only to our processing of personal information when we are acting in a business-to-business capacity. For information on Scanbuy’s privacy practices for the data that powers Scanbuy’s products and services (“Scanbuy Data”), please see the Scanbuy Data Privacy Policy. Information collected during your interaction with us as a consumer of our products and services is governed by our Mobile App Policy.

Please take the time to read through the Policy carefully, so that you can make informed choices concerning your personal information and can better protect your privacy and security. You can jump to particular topics by going to the headings below:

• Notice at Collection
• What Information Do We Collect?
• How Do We Use the Information We Collect?
• Who Do We Disclose Information To?
• What Rights Do You Have?
• What Other Choices Do You Have?
• Children’s Privacy
• Other Important Information
• Changes to This Privacy Policy
• Contact Us

 

1. Notice at Collection

Personal Information We Collect	How We Use Personal Information
Contact and Account Information	Provide and maintain the Site Provide marketing communications Create user profiles based on your preferences Advertising, analytics and reporting Protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law
Demographic Information	Provide and maintain the Site Provide marketing communications Create user profiles based on your preferences Advertising, analytics and reporting Protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law
Geolocation Information	Provide and maintain the Site Provide marketing communications Create user profiles based on your preferences Advertising, analytics and reporting Protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law
Device, Internet, and Network Activity Information	Provide and maintain the Site Provide marketing communications Create user profiles based on your preferences Advertising, analytics and reporting Protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law
Other Information You Voluntarily Choose to Provide	Provide and maintain the Site Provide marketing communications Create user profiles based on your preferences Advertising, analytics and reporting Protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law
Job Applicant Information	Provide and maintain the Site Provide marketing communications Create user profiles based on your preferences Advertising, analytics and reporting Protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law Assess and manage job applications for the selection and contracting of personnel, in order to offer positions that fit your profile
Inferences	Provide and maintain the Site Provide marketing communications Create user profiles based on your preferences Advertising, analytics and reporting Protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law

Scanbuy will retain your information for as long as you continue to interact with our website and  the Site. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Please see Section 6 (“U.S. State Privacy Rights”) of this Policy for information about your rights and choices pursuant to applicable California law.

2. What Information Do We Collect?

Information You Provide To Us. Scanbuy collects information which you provide to us. For example when you create an account or profile, configure your preferences, and when you email, text, call, or otherwise communicate with us. The types of personal information we may collect include:

• Contact and Account Information (e.g. your ScanLife Account User ID, phone number, email address, company name, and information about your preferences).
• Demographic Information (e.g. age, gender).
• Geolocation Information (e.g. GPS data). ScanLife, upon installation on your mobile device, will provide you with an opportunity to give permission to collect such location based information to locate the services and information scanned. If you subsequently choose to stop Scanbuy’s collection of location based information, you can adjust your preferences on your mobile device settings for the ScanLife mobile application at any time.
• Job Applicant Information (e.g. job history, qualifications and other information stated on the resume or job history submitted by the applicant).
• Other Information You Affirmatively Provide To Us (e.g. as part of a message you send to us).

Please consider carefully before disclosing any information that may be personal in nature.

Information Collected By Automated Means. When you access or use our Site, we automatically collect information about you, including Device, Internet, and Network Activity Information using cookies, Web beacons, persistent device identifiers (e.g., Android ID), advertising identifiers (e.g., Google’s “Advertising ID,” Apple’s “IDFA”) and other technologies, as well as server-to-server connections with our partners. This information is used for tracking, advertising, analytics and personalization and optimization of the Site. Additional details about our automatic data collection practices and the different technologies we use to facilitate these activities can be found below:

• Cookies. A Cookie is a string of information that a website saves on a visitor’s computer or mobile device and that the visitor’s browser provides to the website operator each time the visitor returns.  Merchant partner will place a cookie or similar technology on visitor's device when an ad is clicked.
  • Persistent cookies remain on the visitor’s computer or mobile device after the browser has been closed.
  • Session cookies exist only during a visitor’s online session and disappear from the visitor’s computer or mobile device when they close the browser software.
• Persistent Device Identifiers. Persistent device identifiers are unique strings that are associated with the mobile device that you use to connect to a given service. Persistent device identifiers may be modified or disabled by sophisticated users. Some persistent device identifiers can only be reset by wiping the entire device.
• Advertising Identifiers. Advertising identifiers (e.g., Google’s “Advertising ID,” Apple’s “IDFA”) are unique strings associated with your mobile device provided by the operating system. Advertising identifiers may be modified or disabled by users in the operating system settings.

When you access ScanLife, some information such as your Internet Protocol (“IP”) address, internet service provider, operating system, the service from which you arrived, the page you requested, the time and date of your visit, and potentially other site usage statistics will be collected automatically as part of the software processes of ScanLife.

For mobile devices, we collect information regarding the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, applications installed on your mobile device, your use of those applications, the type of mobile internet browser you use when accessing products and services, and  information about the way you use our Site.

The foregoing information itself does not directly identify you, but could potentially be linked with Personal Information that you provide us. These statistics allow Scanbuy to analyze the effectiveness of its Site and make improvements where needed. Upon installation of ScanLife on your mobile device, we will provide you with an opportunity to consent to the collection, use and disclosure of the information described in this Policy. Please note that some information may be required in order for the Site to function properly, and in some cases may be necessary for the Site to function at all. Please see Sections 6 and 7 below to review your choices regarding your information.

Information We Obtain From Other Sources. We obtain information about you from other sources, including publicly available sources and third party partners. We may add this to information we get from the Site.

Information We Derive. We may derive information or draw inferences about you based on the information we collect above.

De-identified and Aggregate Information. Scanbuy may also de-identify some information it collects so that it cannot be readily used to personally identify an individual user. Scanbuy creates standard categories of information by combining information that meets certain criteria into groups. Scanbuy may provide third-party partners (e.g., advertisers, website publishers, and content providers) standard categories of information in order to facilitate interest-based advertising and provide a more relevant advertising experience to consumers. Scanbuy may disclose aggregate or de-identified information in various formats with our partners, and may work with our partners to do research to improve the Site we provide where needed.

3. Cross-Device Matching

Scanbuy may use data we collect to make a deterministic or statistical match of mobile device advertising identifiers and cookie identifiers. For example, we may match a user’s devices if the user logs in to the same online service on multiple devices or web browsers or if the user’s device share similar attributes that support an inference that they belong to the same user. Scanbuy may use data collected from a particular user device that has been matched, as described above, on a different user device. Any choice made by a user with regard to Scanbuy’s collection of data on one device will be reflected on the other device(s) matched to that device.

4. How Do We Use the Information We Collect?

We may use the information collected from and about you to:

• Provide and maintain the Site. Scanbuy may use your information that we collect to process your requests, provide online services, and maintain service quality.
   
• Provide marketing communications. From time-to-time you may receive administrative emails from Scanbuy related to the primary usage of our Site; you may not opt-out of administrative emails
   
• Create user profiles based on your preferences. Scanbuy may use the data collected, as described above, about different websites a user has visited, or content a user has engaged with, and/or mobile apps a user has utilized over time in order to combine the information that meets certain criteria into groups based on demographics, interests, and/or preferences. The particular categories that an identifier might fall into are dynamic and may change over time based on a user’s ongoing browsing history or mobile app use.
   
• Advertising, analytics and reporting. We use personal information to perform data matching and understand your needs so that we can provide you with the highest quality of service. For example, data about a user’s visits to different websites may be used to make inferences about the type of ads and content that may interest the consumer. We and our Clients may also use the data collected for advertising, analytics, or ad reporting purposes or to improve our services.
   
• Protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law. Scanbuy may access, preserve, and disclose your information in connection with your use of the Site or if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to: (a) satisfy any applicable law, regulation, legal process or governmental request, (b) enforce a Terms & Conditions of Use agreement, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues (including, without limitation, filtering of spam), (d) respond to user support requests, or (e) protect the rights, property or safety of Scanbuy, its users, and the public.
  
  Scanbuy may combine all of the information collected from or about you and use it in the manner described in this Policy. 
  
  5. Who Do We Disclose Information To?

We may disclose any personal information and other information we collect from and about you with:

• Subsidiaries and Affiliates. Scanbuy may also disclose your information with our subsidiaries and affiliates for purposes consistent with this Policy. Our subsidiaries and affiliates will be required to maintain that information in accordance with this Policy.

• Service Providers. Scanbuy may use third party service providers perform functions in connection with our Site, as well as to complete transactions on our behalf. Scanbuy may disclose information about you that they need to perform their functions, but they may not use it for other purposes. These third parties will be required to treat your information in accordance with our Policy.
• Advertising and Marketing Companies. We may disclose and allow our third party partners to disclose information that does not directly identify you with other third parties that perform targeted advertising activities across other apps and websites.

• Data Analytic Providers. We may disclose information with our third party business partners. For example, Scanbuy may disclose your device’s precise geolocation, such as GPS data, if you have such a phone feature enabled and have provided us with permission to collect such information, as well as other details about your device (like hardware characteristics, a variety of sensor data, and a list of installed third-party applications) with our partner Sense360 on an ongoing basis, including when the apps are closed. This information is sent with the device’s advertising identifier or another unique device-specific code. Sense360 may use all of this information for market research and other research regarding aggregated patterns, and as further described in its own privacy policy, which has more detail on the entire process. For example, Sense360 analyzes restaurant visit trends to better serve its customers’ needs. You can use your device settings to (i) disable or limit precise geolocation collection for the entire device (which will affect some device functionality) or just particular apps (which may affect the functionality of this app) and/or (ii) disable or limit use of the advertising identifier (which will block that identifier’s transmission to Sense360). To view Sense360’s privacy policy, visit https://sense360.com/privacy-policy.

• Clients: Scanbuy may create custom categories for third parties based on requested demographics and interests (i.e. age, gender, interest). Any time a user deletes their cookies or resets their mobile device advertising identifier, we stop associating new data to those identifiers. However, a user who clears their cookies and/or resets their mobile device identifier is treated as a new user, and new data will be collected and associated with the new cookie identifier or mobile device advertising identifier.

• Organizations in Connection with a Business Transfer. Scanbuy may disclose data if we have a legal obligation to do so or where we believe it is necessary to protect the rights, property, or safety of any person. If Scanbuy becomes involved in a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, we may disclose or transfer all data collected or maintained by us to a third party or parties in connection therewith.

Scanbuy may also disclose aggregate, de-identified data with third parties in connection with reporting and accounting needs as well as with other unaffiliated third parties for various purposes, such as advertising and statistical or educational analysis.

6. What Rights Do You Have?

Depending on a user’s state of residence, under applicable law users may also have the following rights (each of which are subject to various exceptions and limitations):

• Access: This is the right to request up to two times every 12 months, that we disclose to you (i) the categories of personal information we collected about you, (ii) the categories of sources from which we collected the personal information, (iii) the business or commercial purpose for collecting, selling, or sharing your personal information, (iv) the categories of third parties with whom we shared the personal information and (v) the specific pieces of personal information we collected about you.
   
• Correct: This is the right to request the correction of personal information held by us and concerning you.
   
• Delete: This is the right to request the deletion of your personal information held by us and concerning you.  Please note that Scanbuy may be legally required to keep information and not delete it (or to keep information for a certain time, in which case we will comply with any deletion requests only after having fulfilled such requirements). Scanbuy is committed to protecting the integrity of your information from accidental or malicious destruction. Because of this, we may not delete residual copies of your information, even after you delete information from the Site, from our active servers or from our backup systems. For clarity, Scanbuy will not delete information that is de-identified and required for the Site to function properly. You can stop the collection of information by uninstalling the application following the standard uninstall processes of your mobile device or via the mobile application marketplace or network.
   
• Opt Out: Under several U.S. state privacy laws, consumers have the right to opt-out of the “sale” of their personal information (defined very broadly to include situations where we provide personal information to partners who provide advertising services to us) and the “sharing” of personal information in connection with the display of targeted advertising across third party websites. Wwe do not sell or share your personal information. However, if you would like is to stop using your information for our services, you may opt out through the DO NOT SELL OR SHARE MY PERSONAL INFORMATION link on our website. We also honor the Global Privacy Control, a browser-based opt-out signal. We do not respond to other browser based signals that do not meet applicable state law requirements, which may include older Do Not Track signals.
   
• Appeals. You have a right to appeal decisions concerning your ability to exercise your consumer rights.
   
• Submission of Requests.  To exercise one or more of the rights described above you may either (i) follow the instructions provided above, (ii) call us at (844) 297-4013, or (iii) you may request this information in writing using the information under Contact Us below. Scanbuy may require proof of an individual’s identity before we can give effect to any of the above listed rights. To view the metrics related to Consumers exercising their privacy rights in the previous calendar year, click here.
   
• Authorized Agent. You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent identifies himself/herself/itself as an authorized agent and can show written permission from you to represent you. We may contact you directly to confirm that you have authorized the agent to act on your behalf and confirm your identity.
   
• Verification.  Whether you submit a request directly on your own behalf, or through an authorized agent, we will to take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.

For California Users:

• Shine the Light. California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for their own direct marketing purposes.
  
  7. What Other Choices Do You Have?

Scanbuy is committed to providing users with the information they need to make the most informed choices concerning the information we collect and how it may be used. This section describes the users’ choices and how they can exercise them.

(a)   Web Browsers

Users may opt out of Scanbuy’s data collection and use of cookies for interest-based advertising purposes at any time. Users may also manage their advertising preferences in their web browsers by updating the interests and data that Scanbuy or its partners have associated with their browser(s).

After opting out, users will no longer be included in the targeted advertising activities conducted via the Site. Opting out will not prevent future online ads and content from being delivered, but these ads and content may not be as personalized or relevant to the user.

Please note that the opt-out tools discussed are cookie-based, and only prevent the collection of information pertaining to users on the browser on which they were installed, will only function as described if the user’s browser is set to accept third-party cookies, and may not be as reliable if the user’s cookies are automatically disabled or removed (e.g., some mobile devices and operating systems). If the opt-out cookie is deleted from a browser, the collection of information by participating members will resume until an opt-out cookie is reinstalled on that browser.

The Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”) have established rules about interest-based advertising.

To opt-out of the collection of information by NAI members, visit http://www.networkadvertising.org/choices/

To opt-out of the collection of information by DAA members, visit http://www.aboutads.info/choices/

 (b)   Mobile Apps

Mobile apps do not accept cookies, and as such the opt-out methods described above may not work for mobile apps. Users who would like to exercise their opt-out choice for mobile apps, may choose to download the AppChoices App provided by the DAA relevant to their mobile platform using the links below on each of their mobile devices and by setting their preferences within each app:

To download AppChoices for iOS devices click here.

To download AppChoices for Android devices click here.

To download AppChoices for Amazon devices click here.

Users should note that resetting their mobile device advertising identifiers will undo their choices made in the AppChoices App, and they will need to reset their preferences to retain those choices.

(c) Cross-Device Matching

Users who wish to opt out of Scanbuy’s cross-device matching, can do so by using the tools described in subsections (a) and (b) above. Once a User has opted out using the tools described above, Scanbuy will honor any choice made by a user with regard to Scanbuy’s collection of data on any device(s) which had been matched to that user. It may be necessary to opt out separately on each device and browser that a user uses in order for their opt out choices to be reflected across all of their browsers and devices.

(d) Scanbuy Partners

Some of Scanbuy’s partners provide opt-out tools which are cookie-based. If you’d like to opt-out of the services of our third party partners who provide such an opt-out mechanism, please click here to view their privacy policies, which include opt out instructions. 

8. Children’s Privacy

Scanbuy understands the importance of protecting the privacy of children, especially in the online environment. The Site intended for adult use only and we do not knowingly solicit, collect, or maintain data from or market to children under the age of 18. Similarly, Scanbuy does not allow its third-party data providers from knowingly sharing data relating to children under the age of 18. If we become aware that we have collected or received data relating to a child, Scanbuy will take reasonable steps to delete it.

9. Other Important Information.

Data Security. Scanbuy uses generally accepted industry security standards including physical, electronic, and administrative safeguards that are designed to help protect the data that we collect, use, and retain. For example, Scanbuy limits access to information to its authorized employees and contractors who need to know that information in order to operate, develop or improve its products and services. Scanbuy will store all the information you provide on secure servers. Information relating to electronic transactions entered into via our website and the Site will be protected by encryption technology. Please be aware, that although Scanbuy makes every endeavor to provide reasonable security for information it processes and maintains, no security system can prevent all potential security breaches. No method of transmission over the internet, or method of electronic storage, is 100 percent secure. Please consider carefully before disclosing any personal information.

Links to Third Party Websites and Services. For your convenience, we may provide links to third-party websites or services that are not governed by this Policy. To the extent that any linked third-party websites or services you visit are not owned or controlled by Scanbuy, we are not responsible for those websites or services content or information practices. We encourage you to review the privacy policies of any site or services before providing any personal information. Scanbuy is not liable for any information collected, used or disclosed by the user’s mobile device manufacturer or service provider. Your internet service provider or mobile carrier network may have access to the communications, such as text messages, phone calls or emails, sent using the mobile device. For information regarding your service provider’s or carrier’s treatment of your information, please consult their privacy policies, which we encourage you to do. If you decide to use third party applications on your device, any information those applications collect may be sent to third parties and this Policy does not apply. However, third party applications may have their own privacy policy that we encourage you to review

Jurisdictional Issues. Currently, the Site is only performed on data collected and maintained within the United State, Canada and Mexico, however, all of the disclosures mentioned above may result in the international transfer of personal data to countries or regions with data protection laws that differ from those in a user’s country of residence. In cases where consumers’ personal data is transferred outside of their country of residence, we will ensure that there are adequate safeguards in place to protect their data.

10.Changes to this Privacy Policy

Scanbuy reserves the right to change this Policy from time-to-time. Be sure to check this page periodically for updates. If Scanbuy makes any changes to this Policy, we will update the “Effective Date” listed at the top of this page. If Scanbuy makes significant or substantial changes to this Policy, we will obtain your express consent prior to your continued use of the Site. Please be advised that failure to consent may result in the Site not functioning properly or not functioning at all.

11. Contact Us

Please contact us with any questions or comments about this Policy or our privacy practices at: privacy@scanbuy.com or write to us at:

Scanbuy
10 E. 39^th Street
Floor 10
New York, New York 10016
USA
Attn: Legal Dept.

Consumer Engagement