The types of Personal Information we may collect (directly from you or fromThird-Party sources) and our privacy practices depend on the nature of the relationship you have with SourceScrub and the requirements of applicable law.Some of the ways that SourceScrub may collect Personal Information include:
We endeavor to collect only that Personal Information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
SourceScrub collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and employees (collectively“Individuals”).
Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an Account with SourceScrub, responding to surveys, requestingServices or information, or contacting us directly, we may ask you to provide some or all of the following types of Personal Information:
We acquire, hold, use, and Process PersonalInformation about Individuals for a variety of business purposes, including:
To Provide Products, Services, orInformation Requested.
SourceScrub may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
SourceScrub may use Personal Information about you for its administrative purposes, including to:
MarketingSourceScrub Products and Services.
SourceScrub may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. SourceScrub may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
Research and Development.
SourceScrub may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, SourceScrub may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing.
Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on SourceScrub’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
Services via Mobile Devices.
Anonymous and Aggregated Information Use.
SourceScrub may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access SourceScrub’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and SourceScrub may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within SourceScrub and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
LEGAL BASES FOR PROCESSING EUROPEAN INFORMATION
If you are located in the European EconomicArea or the United Kingdom, we only Process your information when we have a valid “legal basis”, including when:
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and SourceScrub does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
SourceScrub’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
We Use Vendors and Service Providers.
We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. SourceScrub has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
SourceScrub may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. SourceScrub may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with SourceScrub. SourceScrub requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which SourceScrub provided them.
Displaying to Other Users.
The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you. We are not responsible for privacy practices of the other users who will view and use the posted information.
Marketing – Interest-Based Advertising and Third Party Marketing.
Through our Services, SourceScrub may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-SourceScrub related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may
be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 6 below.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures).
We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce SourceScrub policies or contracts; (v) to collect amounts owed to SourceScrub; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
Merger, Sale, or Other Asset Transfers.
All Personal Information collected via or by SourceScrub may be stored anywhere in the world, including but not limited to the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to SourceScrub, you consent to the storage of your Personal Information in these locations. Your information may be also held, processed and accessed outside the European Economic Area or the United Kingdom to countries that have not been determined by the European Commission to provide an adequate level of data protection, for instance the United States. In any such transfer, SourceScrub will ensure that appropriate data protection safeguards (e.g. European Commission’s Standard Contractual Clauses) are in place. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please contact us using the contact information below. We may also transfer information from the European Economic Area or the United Kingdom to third countries as needed to perform the Services that you have requested from us, or with your consent.
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to SourceScrub’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting privacy@SourceScrub.com. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics.
You may inquire as to whether SourceScrub is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is. Where otherwise permitted by applicable law, you may send a letter to SourceScrub at “150 Post St. Floor 6, San Francisco, CA 94105” to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by SourceScrub. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws.
Although SourceScrub makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which SourceScrub is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If SourceScrub determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, SourceScrub will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
Your European Privacy Rights. If you are located in the European Economic Area or the United Kingdom, you have the additional rights described below:
We take steps to ensure that your information is treated securely. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the U.S. and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy. Your information may be also held, processed and accessed outside the European Economic Area or the United Kingdom to countries that have not been determined by the European Commission to provide an adequate level of data protection, for instance the United States. In any such transfer, SourceScrub will ensure that appropriate data protection safeguards (e.g. European Commission’s Standard Contractual Clauses) are in place. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please contact us using the contact information below. We may also transfer information from the European Economic Area or the United Kingdom to third countries as needed to perform the Services that you have requested from us, or with your consent.
If you are based in the European Economic Area or the United Kingdom and feel that SourceScrub is not abiding by the terms of this Policy, please contact SourceScrub at the contact information provided above.
If you are a California resident, you may exercise certain rights by submitting requests to know and access the Personal Information we have collected about you, to delete Personal Information, to opt-out of the sale of personal information, and to not be discriminated against for exercising these rights. Please visit our California Resident Privacy Notice for supplemental information and disclosures regarding rights of California residents
The following capitalized terms shall have the meanings herein as set forth below.