Effective Date: December 31,2019
Scanbuy helps 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.
Scanbuy collects information from the Site services that generally are considered non-personally identifiable information (“Non-PII”) in a variety of ways, including through the use of browser cookies, pixel tags, and server-to-server connections with our partners. The data that we collect for our Service may include, but is not limited to, your IP host address, the date and time of the relevant online activity, specific location information of your device when available, pages viewed, browser type, the referring URL, Internet Service Provider, mobile identifiers (e.g., Apple IDFA and Android Advertising ID), and your device’s operating system. We also collect information that you affirmatively provide to us (for example, as part of a message you send to us). Please consider carefully before disclosing any information that may be personal in nature.
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 information we may collect include: your ScanLife Account User ID, mobile phone number, email address, account information, age, gender, demographic information, information about your preferences and any other information you affirmatively provide to us (for example, as part of a message you send to use).
Scanbuy may be able to collect location information, such as GPS data, if you have such a phone feature enabled and have provided us with permission to collect such information. ScanLife, upon installation on your mobile device, will provide you with an opportunity to give permission to collect such location based information. 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.
The information you provide us may include Personal Information, please consider carefully before disclosing ANY information. Please see Scanbuy Choices below to review your choices regarding your information.
Scanbuy collects certain types of Non-PII whenever you use ScanLife. For example, 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 anonymous information about the way you use our Site services; we may share and allow our third-party partners to share Non-PII with other third parties that perform targeted advertising activities across other apps and websites. Scanbuy collects your IP address to identify the country in which you are using ScanLife in order to provide you with the most relevant information in response to your requests.
Scanbuy may also anonymize 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 share aggregate or anonymous information in various formats with our partners, and may work with our partners to do research to improve the Site products and services we provide were needed.
Scanbuy may process information about you, which is described in the table below.
Device Identifiable Information (“DII”): Any data that is linked to a particular browser or device if that data is not used, or intended to be used, to identify a particular individual. DII may include, but is not limited to, unique identifiers associated with browsers or devices, such as Cookies, Mobile Advertising Identifiers, and IP addresses, where such data is not linked or intended to be linked to Personally Identifiable Information.
Emails: Any email address that you affirmatively provide to us.
Location Information: Precise geolocation from or about a device (e.g., latitude-longitude coordinates).
Behavioral Data: Information about the ways in which you use the Site services.
Scanbuy collects information from you, some of which may constitute Personal Information. This information is collected directly from you and/or your device(s).
Scanbuy collects (i) information that you affirmatively provide us, and (ii) information automatically collected 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. Automatically collected information are used for tracking, advertising, analytics and personalization and optimization of the Site services. Additional details about our automatic data collection practices and the different technologies we use to facilitate these activities can be found below:
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.
Scanbuy may access, preserve, and disclose your information in connection with your use of the Site services 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. 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.
Scanbuy may use third party service providers and business partners to perform functions in connection with the Site services. Scanbuy may share information about you that they need to perform their functions, but they may not use it for other purposes.
As described above, Scanbuy may create aggregate level and/or anonymous information, which it may provide to third parties to provide targeted advertising and analytics services on or within our Site, or across others sites and applications. These entities may use technologies to collect information about your use of our Site, including device attributes such as: operating system, hardware version, device settings, IP address, time zone, device carrier, applications installed on the device, and device advertising identifiers. We may share and allow our third party partners to share this Non-PII with other third parties that perform targeted advertising activities across other apps and websites. Please see Opt-Out and other Choices & Legal Rights below to review your choices regarding your information.
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 share or transfer your information to a third party or parties in connection therewith.
Scanbuy may disclose data collected through or in connection with your use of the Site with various parties for certain purposes, as described below.
In the past twelve (12) months, Scanbuy has shared information about Consumers with the following categories of third parties:
In cases where your information is transferred outside of your country of residence, we will ensure that there are adequate safeguards in place to protect your data.
Scanbuy relies on one of the legal bases below in order to process consumers’ data:
Scanbuy will retain your information for as long as you continue to interact with the Site. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
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.
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”), the Digital Advertising Alliance (“DAA”) and the European Interactive Digital Advertising Alliance (“eDAA”) have established rules about interest-based advertising.
To opt-out of the collection of aggregate level and/or anonymous information by NAI members, visit http://www.networkadvertising.org/choices/
To opt-out of the collection of aggregate level and/or anonymous information by DAA members, visit http://www.aboutads.info/choices/
To opt-out of the collection of aggregate level and/or anonymous information by eDAA members, visit http://www.youronlinechoices.eu/
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.
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.
If you would like to review the Privacy Policies of our third party partners, please visit the links below:
Some of Scanbuy’s third party partners provide opt-out tools which are cookie-based. If you would like to opt-out of the services of our third party partners who provide such an opt-out mechanism, please visit the links below and follow the relevant instructions:
To opt-out of PushSpring’s use of aggregate level and/or anonymous information, click here.
Please note that cookie-based opt-out tools prevent the collection of information pertaining to you on the browser on which they are installed and will only function as described if your browser is set to accept third-party cookies, and may not be as reliable if your 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.
To opt-out of Scanbuy’s sale of Personal Information to third parties, click DO NOT SELL MY PERSONAL INFORMATION.
Depending on a user’s country of residence, under applicable law users may also have the right to:
Users who are interested in exercising one or more of these should note that Scanbuy may require proof of an individual’s identity prior to giving effect to the above-listed rights. Scanbuy wants to give users the easiest ways to update, amend or delete their information – unless Scanbuy has to maintain that information for legitimate business or legal purposes. 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). We are committed to protecting the integrity of consumer information from accidental or malicious destruction. Because of this, Scanbuy 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 anonymized.
To request the information that Scanbuy may have about you that is associated with your device and/or any devices that have been matched, click here.
To request the deletion of information that Scanbuy may have about you that is associated with your device and/or any devices that have been matched, click here.
Users residing in the EEA who are dissatisfied with the way in which Scanbuy manages their information or any privacy requests that they have made, have the right to submit a complaint to the Data Protection Authority (“DPA”) in their country of residence or the location where the issue that is the subject of their complaint occurred. Such users can find the contact details of all national DPAs by clicking here.
Consumers who are California residents, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information (as defined by California law) by Scanbuy to a third party for the third party’s direct marketing purposes.
Consumers who are California residents, under California Civil Code Section 1798.100(a) have the right to request that Scanbuy disclose to them the Personal Information which Scanbuy has collected.
Consumers who are California residents, under California Civil Code Section 1798.105(a) have the right to request that Scanbuy delete any Personal Information which Scanbuy has collected.
Consumers who are California residents, under California Civil Code Section 1798.110 have the right to request that Scanbuy, as a business that collects Personal Information, disclose information about the Personal Information collected.
Consumers who are California residents, under California Civil Code Section 1798.115 have the right to request that Scanbuy, as a business that sells Personal Information, disclose information about the Personal Information collected and sold.
Consumers who are California residents, under California Civil Code Section 1798.120 have the right to opt out from Scanbuy’s sale of their Personal Information to third parties. Personal Information retained by Scanbuy may be sold to third parties, however Consumers have the right to opt out at any time. Scanbuy does not knowingly collect and/or sell Personal Information of people under the age of 18. In the event that a consumer opts out from Scanbuy’s sale of their Personal Information to third parties, Scanbuy will respect such choice and will not request re-authorization to sell their Personal Information for at least 12 months from the date the consumer had opted out. California Civil Code Section 1798.135 requires that Scanbuy provide you with a link allowing you to exercise your opt out rights under Section 1798.120, through the provision of a DO NOT SELL MY PERSONAL INFORMATION link.
To exercise one or more of the rights described above you may either (i) follow the instructions provided above at Section 9€, (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.
Scanbuy understands the importance of protecting the privacy of children, especially in the online environment. The Services are 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.
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 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.
10 E. 39th Street
New York, New York 10016
Attn: Legal Dept.