Scamnetic™ Privacy Policy
Last updated September 23, 2024
This Privacy Policy describes the types of Personal Information that Scamnetic Inc. (“Scamnetic™,” “we,” “our,” or “us”) collects from and about you, how we may use and disclose such information, and your choices and legal rights with respect to such information. We ask that you carefully review this Privacy Policy, as it applies to the websites (each a “Site”) and mobile applications (each an “App”) as well as the services owned, operated, and/or provided by Scamnetic that display or link to this Privacy Policy, including our offline locations (collectively, our “Services”).
By using our Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree, please do not use our Services.
For purposes of this Privacy Policy, “Personal Information” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, and includes “personal data” or similar terms as defined in applicable law.
1. NOTICE AT COLLECTION OF PERSONAL INFORMATION
We collect the categories of Personal Information identified below. As indicated in the chart, for some of these categories, we “sell” or “share” (as such terms are defined in California law) Personal Information for marketing, advertising, or fraud detection purposes to business partners and third parties, such as data analytics providers and law enforcement agencies. We do not knowingly sell or share personal information about persons under the age of 18. Please click here to opt out of the sale or sharing of your Personal Information, including targeted advertising. You may also choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt out.
| A. Category of Personal Information Collected | Do we sell or share the category of Personal Information to business partners and third parties? |
|---|---|
|
Identifiers/biographical information, including name, postal and email address, phone number, online identifiers, Internet Protocol (“IP”) address, and other similar identifiers. |
Yes |
|
Personal information categories listed in the California Customer Records statute, such as your credit or debit card number. |
No |
|
Characteristics of protected classifications under California or Federal law, including age. |
No |
|
Commercial information, including items purchased, obtained, or considered and other purchasing or consuming histories or tendencies. |
Yes |
|
Internet or other electronic network activity information |
Yes |
|
Geolocation data |
No |
|
Biometric information |
No |
|
Audio, electronic, visual, thermal, olfactory, or similar information |
No |
|
Professional or employment-related information |
No |
|
Inferences, meaning inferences drawn from the above-listed categories of Personal Information to create a consumer profile reflecting consumer preferences or characteristics. |
Yes |
|
Sensitive Personal Information, means Personal Information that reveals social security, driver’s license, state identification card, or passport number, genetic information, biometric information, account log-in, financial account, debit card, or credit card, password, or credentials allowing access to an account, financial information (including account number), precise geolocation, racial or ethnic origin, national origin, treatment, union membership, religious or philosophical beliefs, status as transgender or non-binary, sexuality, status as a victim of crime, citizenship or immigration status, contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; as well as the processing of biometric information for the purpose of uniquely identifying a consumer, and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. We do not use or disclose such information for the purpose of inferring characteristics about you or for any purpose other than the limited permissible purposes set forth in the regulations implementing California law. Such purposes include providing our Services and verifying, maintaining the quality of, and improving our Services. |
No |
B. The Business and Commercial Purposes for Which We Collect and Use Your Personal Information:
- To provide you with our Services
- To process your payments and fulfill your orders
- To create, maintain, customize, and secure your account with us
- To communicate with you, such as through bots, including to respond to your inquiries/requests and request feedback from you, and to send you important updates and messages about changes to our Services, this Privacy Policy, and/or other applicable terms and conditions
- To review the usage and maintain the operation of our Services
- To conduct analysis and develop and/or improve our products and Services
- To monitor, protect, and maintain the security and integrity of our Services and our business, such as protecting against and preventing fraud, unauthorized transactions, claims and other liabilities
- To comply with applicable laws and regulations and respond to lawful requests and communications from law enforcement and other government officials
- To carry out sales and business transactions in which information held by us is among the assets transferred or is otherwise relevant to the evaluation, negotiation, or completion of the transaction
- To protect our rights, privacy, safety, property and/or those of others
- To fulfill any other purpose for which you provide your Personal Information or as explained to you at the point of information collection
- To provide you with customized content or targeted offers
- To send you information, newsletters, and marketing/promotional material from us and, or on behalf of, our marketing partners and affiliates
When verification is required, you authorize your wireless operator to disclose to Scamnetic™ and its third-party service providers your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, solely to verify your identity and prevent and detect fraud.
C. Retention
We will retain your Personal Information for as long as reasonably necessary to provide you with our Services that you request, for purposes of improving our services and algorithms for scam and fraud prevention with your consent, for marketing purposes unless you opt out as described in our Privacy Policy, or otherwise where permitted or required in accordance with applicable law. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. What this means in practice will vary between different types of information, and when we consider our approach we take into account ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.
2. PERSONAL INFORMATION WE COLLECT
There are several ways we may obtain Personal Information about you, including through (A) information you provide to us; (B) information we automatically collect; (C) information we receive from third parties; and (D) combining information from different sources. This includes data that identifies you personally whether directly or indirectly.
We collect Personal Information as listed in the above Notice at Collection from you as follows:
- When You Use our Services. We collect Personal Information from you when inquire about, create an account for, or use the Services.
- When You Make a Purchase. If you purchase services from us, we or our third-party payment processors collect a payment card number or other payment information.
B. Information We Automatically Collect
When you visit and interact with our Services, we or our third-party advertising and analytics partners and service providers may use a variety of technologies, such as cookies, tags, SDKs or scripts, to collect certain information regarding your activity.
The specific types of information that we and our partners and service providers may automatically collect when you visit and interact with our Services include:
- Device and Browser Information. This includes your device’s IP address and/or other unique identifiers, browser type, device type, internet service provider, and operating system.
- Location Information. When you access our Services from a mobile device, your device’s approximate location (derived from your device’s IP address or other signals) may be collected.
- Usage Information. When you interact with our Services, certain information may be collected, including the date and time of your visit, the pages you view immediately before and after you access our Services, the areas or pages of our Services that you visit, the amount of time you spend viewing or using our Services, recordings of chat sessions (including with the involvement of bots), and other Site usage information. We (or our third-party vendors) may use tools and software to monitor and record information (including screenshots and videos) about your interactions with our Services, including keystrokes, mouse movements, form field entries, and overall engagement with our Services.
- Marketing Information. If you receive an email from us, information may be collected about your interactions with the message (e.g., whether you opened, forwarded, or clicked through to our Site).
- Third-party analytics technologies. We may use third-party analytics and tracking tools to better understand who is using our Services, how people are using them, and how to improve their effectiveness as well as the effectiveness of any related content.
Cookies and Other Similar Technologies: “Cookies” are text files that are placed on your browser by the websites that you visit. Cookies are used for various purposes, including to distinguish you from other users, make your site navigation more efficient, help remember your preferences, enhance your browsing experience, and improve the use and functionality of our Sites and related content. They can also enable the delivery of relevant and personalized advertisements to you across the Internet.
Please note that cookies (and other similar technologies) provided by third parties may be placed on our Sites and the providers of these technologies may combine information collected from your interaction(s) with our Services with information they collect from other sources and use the combined information for analytics and/or advertising purposes.
To learn more about your choices regarding the automatic collection and use of your information as you browse our Services, please see the Your Privacy Choices and Rights section below.
C. Information We Receive from Third Parties
We may receive Personal Information from other sources. Our third-party sources may include:
- Our Business Partners, including companies that co-sponsor our promotions.
- Our Marketing/advertising and analytics partners, including online advertising networks and analytics providers.
- Social Media Platforms (note that the information we receive from such platforms is dependent upon their policies and your settings on the platforms).
- Other Companies that provide Personal Information to supplement what we already know about you, including data aggregators.
We use Google Workspace APIs to monitor Gmail accounts for scam content with your consent. Scamnetic does not retain data obtained through Google Workspace APIs to develop, improve, or train the Services.
We may combine Personal Information that we receive from various sources. For example, we may combine Personal Information that we collect from you offline with Personal Information we collect from you through our Services. Similarly, we may combine Personal Information that we receive from third parties with Personal Information we already have about you. We use, disclose, and protect combined Personal Information as described in this Privacy Policy.
3. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
In addition to the sale or sharing of Personal Information as described above in the Notice at Collection, we may disclose each category of Personal Information that we collect to the following categories of recipients for business purposes:
- Our Service Providers. We disclose your Personal Information to our service providers that provide business, professional, marketing, analytics, or technical support services to us, help us operate our business and the Services, or administer activities on our behalf. We require our service providers to only use your Personal Information in connection with providing services to Scamnetic.
- Our Research Partners. We disclose your Personal Information to our research partners, including those that administer surveys or conduct research projects in partnership with us or on our behalf.
In certain circumstances, we may disclose each category of your Personal Information to:
- Competent Governmental, Regulatory, and Public Authorities. We may disclose your Personal Information to government and law enforcement authorities, in each case to comply with legal or regulatory obligations or requests.
- Relevant Third Parties as Part of a Corporate Transaction. In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), we may disclose or transfer your Personal Information to certain third parties, such as the acquiring entity and its advisers.
- Other Third Parties. We will disclose your Personal Information to other third parties at your direction or with your consent. Additionally, we will disclose your Personal Information as we believe necessary or appropriate to: (a) comply with applicable law; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety, or property, and/or those of you or others; and (e) allow us to pursue available remedies or limit damages that we may sustain.
- We may disclose your Personal Information for other reasons that we will describe at the time of information collection or prior to disclosing your information.
Please note that we may de-identify or aggregate Personal Information so that it will no longer be considered Personal Information and disclose such information to other parties for purposes consistent with those described in this Privacy Policy.
4. YOUR PRIVACY CHOICES AND RIGHTS
You have the ability to make certain choices about how we use your Personal Information, as follows:
A. Unsubscribing from our Marketing and Promotional Communications
From time to time, we may send you marketing and promotional communications, including special offers from us or our partners. If you no longer wish to receive promotional and marketing emails from us, you may opt out of such communications at any time by following the opt-out instructions included in any promotional or marketing email you receive from us.
B. Privacy Rights and Requests
Depending on your location of residence, you may have certain rights in relation to your Personal Information, including:
- Right to Know: You may have the right to know what Personal Information we have collected about you, including the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information (including the names of such third parties), the categories of Personal Information disclosed to third parties, and the specific pieces of Personal Information we have collected about you. Please note that we may not be required to respond to your requests “to know” or access specific pieces of Personal Information more than twice in any 12-month period.
- Right to Data Portability: You may have the right to access your information in a portable format.
- Right to Delete: You may have the right to request that we delete Personal Information that we have collected from you, subject to certain exceptions.
- Right to Correct: You may have the right to correct inaccurate Personal Information that we may maintain about you, subject to appropriate verification.
- Right to Opt Out of Certain Types of Personal Information Uses and Disclosures: You may have the right to opt out of the “sale” or “sharing” of your Personal Information, or the use and disclosure of your Personal Information for “targeted advertising” (as these terms are defined in applicable law).
Please note that, where permitted under applicable law, we may decline a request (other than for opt outs) if we are unable to verify your identity (or an agent’s authority to make the request) and confirm the Personal Information we maintain relates to you.
If you are interested in exercising one or more of the rights outlined above, please click here or you can contact us at [email protected]. Please put the statement “Your Privacy Rights” in the subject field of your email. We may take steps to verify your identity before responding to your request by asking you a series of questions about your previous interactions with us. Submitting a privacy rights request does not require you to create an account with us.
We will not discriminate against you if you decide to exercise your privacy rights.
C. Agent Requests
Only you, or someone legally authorized to act on your behalf, may submit a request related to your Personal Information. You may also submit a request on behalf of your minor child.
Depending on your location of residence, you may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf. Scamnetic retains the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity.
D. Opt-Out Requests
You may request to opt out of the sale or share of your Personal Information, or of targeted advertising, at any time by clicking the “Do Not Sell or Share My Personal Information” link here or at the bottom of our Services’ homepages, or you can email us at [email protected].
Submitting an opt-out request does not require you to create an account with us.
Alternatively, you can use certain preference signals to exercise your sale and sharing opt-out right automatically with all businesses that you interact with online, including Scamnetic. If you enable a browser-based opt-out preference signal, such as Global Privacy Control (GPC), upon receipt or detection, we will treat the signal as a valid request to opt out of the sale or sharing of personal information linked to that browser and any consumer profile we have associated with that browser. Please note that if you use different browsers or browser profiles, you will have to enable the signal on each browser or profile.
E. Right to Appeal
Depending on your location of residence, you may have the right to appeal a decision we have made in connection with your privacy rights request. To appeal a decision, please contact us at [email protected].
F. Additional Notice to EEA and UK residents
For residents of the European Economic Area and United Kingdom, Scamnetic is the controller responsible for processing your Personal Information.
- Legal Basis for Processing: Applicable law in certain jurisdictions requires us to set out the “legal basis” that we rely on to collect and use your Personal Information. Where applicable, the legal bases upon which we rely on in order to collect and use your Personal Information are as follows:
- Consent: We may collect, use, and disclose your Personal Information on the basis of the consent that you provide us at the point of information collection or disclosure. You have the right to revoke your consent at any time.
- Legitimate Interests: We may collect and use your Personal Information to the extent necessary to carry out our legitimate interests (or those of a third party), provided that such interests do not outweigh your interests or fundamental rights and freedoms. For example, we may collect and use your Personal Information in reliance on a legitimate interest in detecting and preventing fraud and other harmful activities.
- Privacy Rights and Requests: Under applicable law, you may have certain rights in relation to your Personal Information, including:
- Right to Access: You have the right to request access to, or copies (and transmission) of, the Personal Information we hold about you and the purposes for which we are using it.
- Right to Rectify: You have the right to correct inaccurate Personal Information that we have collected from and maintain about you, subject to appropriate verification.
- Right to Erase: You have the right to erase Personal Information pertaining to you, under certain conditions. We will assess any deletion request after verifying your identity and work to respond within one calendar month, and let you know if we need additional time.
- Right to Object: You have the right to object to processing the Personal Information we process, under certain conditions.
- Right to Restrict: You have the right to restrict the processing of your Personal Information, under certain conditions.
- Right to Data Portability: You have the right to receive the data we have collected from you. Under certain conditions, you may request that we transfer your Personal Information to another organization, or directly to you.
- Right to Lodge a Complaint: You have the right to file a complaint with the supervisory authority in your jurisdiction.
At any time, you may request or assert any of the rights above by emailing us at [email protected]. If you believe there has been a violation of your privacy rights, please contact us. You have the right to lodge a complaint with a supervisory authority.
5. EXTERNAL LINKS
Our Services may have links to third-party services, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites.
6. CHILDREN’S PRIVACY
Our Services are intended for a general audience. We do not direct our Services to children under eighteen (18), nor do we knowingly solicit or collect any Personal Information from children under the age of eighteen (18). If you are a parent or legal guardian and think that your child has given us data, or you have you can contact us in writing or by email as provided below under the section titled “How to Contact Us.” Please mark your inquiries “Children’s Privacy Information Request.” If we learn that a minor has provided Personal Information through our Services, we will use reasonable efforts to remove such information from our files.
7. DATA SECURITY
We have implemented physical, administrative, and technical safeguards to maintain the security, confidentiality, and integrity of your information. However, as no transmission of information over the internet is absolutely secure, we cannot guarantee the safety of your information.
8. INTERNATIONAL TRANSFERS
Scamnetic is a global business and it, or its service providers, may process, transfer, and store information about our users on servers located in a number of countries inside of the EEA or UK, or outside of the EEA or UK, including in the United States. When you use our Service, your data may be transferred to locations within the EEA or UK, or outside of the EEA or UK. In some of these locations, data protection laws may be less stringent than in the EEA or UK. To ensure that your Personal Information is adequately protected, we only transfer your Personal Information subject to suitable safeguards being in place.
In particular, where we transfer your information outside the EEA or UK, and where required by law, we implement an approved data transfer mechanism in place, such as the standard EU Model Clauses. To find out more about how we safeguard your information (including obtaining a copy of such safeguards) in relation to transfers outside the EEA, please contact us via the details in the “How to Contact Us” section below.
9. REVISIONS TO THIS PRIVACY POLICY
We reserve the right, in our sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Policy at any time. When we do, we will post the change(s) to our Services. Your continued use of our Services following the posting of changes to these terms means you accept these changes. If we change the Privacy Policy in a material way, we will provide appropriate notice to you.
10. HOW TO CONTACT US
If you have any questions or concerns about this Privacy Policy or the practices described herein, you may contact us at [email protected].